Privacy Policy

1. Introduction

Zerobalance Technologies Private Limited, a private limited company having its registered office at F/402 Satva Apartments, Shantivan, Paldi, Ahmedabad, Gujarat - 380007 (hereinafter referred to as “We”, “Us”, “Our”, “Company”, "Zeroabalance", "spac" or "SPAC") which owns and operates the website www.getspac.app and/or the mobile application ‘SPAC’ available at Android/ iOS platforms (collectively referred to as the “Online Platforms”) for the purpose of providing digital payment solutions to any natural or legal person  (hereinafter referred to as “You”, “Your”, “User”, “Customer”) is committed to protecting your privacy and the information that you share while using the Online Platforms. We value the trust you place in us, that’s why we maintain the highest security standards for securing the transactions and your information.This Privacy Policy (hereinafter referred to as “Privacy Policy”) specifies the manner in which personal information and/ or sensitive personal information or any other information are collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by SPAC. This Privacy Policy does not apply to information that you provide to, or that is collected by, any third-party through the Online Platforms, and any third-party sites that you access or use in connection with the services offered on the Online Platforms.This Privacy Policy shall be construed in accordance with the provisions of the Information Technology Act, 2000 and rules made thereunder including the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended thereof and other applicable law enacted from time to time.Please read the Privacy Policy carefully prior to using, signing up or registering on our Online Platforms or accessing/availing our services, content, features, technologies or functions offered or made available on the Online Platforms (collectively referred to as “Services”).

2. Scope of this Policy

A user who has visited the Online Platforms, and/or who may have further agreed to avail the Services shall come under the purview of the scope of this Privacy Policy. This Privacy Policy applies to all forms of personal information, physical and digital, whether collected or stored electronically or in hardcopy.

3. Information Collected

We may collect such information about you which enables us to operate our business and deliver and improve our Services including but not limited to the information that personally identifies you including name, contact details, identification information, organisation, department, any financial information including inter alia credit card, debit card details, bank account and know your customer (KYC) documents, biometrics, and information relating to the use of  Online Platforms including device information, technical information, transactional information (collectively referred to as the “Personal Information”). Thus, we may collect and process the following information about you:a. Information You Give UsYou may be required to give us Personal Information about yourself while visiting the Online Platforms and/or availing any of our Services or corresponding with us by phone, e-mail, chat or when we troubleshoot problems reported by you. The information you give us may include without limitation: Personal details, including but not limited to date of birth, age, marital status, birthplace, nationality, mother tongue, photographs, signature specimen and Government-issued identifiers including but not limited to Aadhar, PAN.
Contact information, including but not limited to name, postal address, telephone number and email address;
Financial information, including but not limited to bank account details, credit/debit card details, credit score/ credit information report, e-KYC, billing information, tax information and payroll information (as applicable); and
Other information, that SPAC is required to collect as per specific mandate from partner bank/non bank/PPI issuer or as a requirement under applicable law, regulation, rule or statute in India
We may also occasionally require you to participate in optional surveys. Your Personal Information may be collected through such surveys. We may also require additional information about you for performing ongoing due diligence (necessitated under the applicable law) based on your risk assessment, transaction value, etc.You must ensure that all your data and/or information shared with us is accurate, correct and complete, at all times. You understand that you must promptly inform us of any changes to your data and/or information which may impact your use of our Services. We shall not be liable or responsible for any loss or damage that may occur to you or other third parties on account of provision of incorrect data and/or information provided by a user.b. Information We Collect About YouWith regard to each of your visits to any of the Online Platforms, we may automatically collect and analyse the following demographic and other information:Device Information: Information obtained with consent from your mobile phone or other access device. It includes device ID, device type, geo location information, connection information, mobile network information, transactional and promotional SMS, communication information including contacts and call logs.
Technical information: Information including the Internet Protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other similar information.
Access Information, Information including the full Uniform Resource Locators (URL) clickstream to, through and from the Online Platforms including date and time; information about transactions and trades executed or attempted to be executed by you; material or information that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information including scrolling, clicks, and mouse-overs, and methods used to browse away from the page and any phone number used to call our customer service number.
Transactional Information: For enabling you to make payments while accessing Services through our Online Platforms, we may store your financial information such as your bank account or details mentioned on your credit cards or debit cards, or other payment instrument details etc. that are required for a successful transaction. We also store transaction details such as amount spent, counterpart details, beneficiary information, account balance, transaction ID, date and time of transaction. Further, we may also store information relating to your income, lifestyle levels and usage pattern.
Correspondence Information: For quality and training purposes or for its own protection, SPAC may monitor or record its telephone conversations with you or anyone acting on your behalf. By communicating with SPAC, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.
Cookies: We also collect anonymous information through our use of cookies and web beacons. We may collect and store any information you provide us when you use our Services, including when you add information on a web form, add or update your account information, participate in community discussions, chats, or dispute resolutions, or when you otherwise correspond with us regarding our Services.
In addition to above, for the mobile version of the App, we may collect any other authorization or information that enables SPAC to provide a smooth mobile experience, including but not limited to, SMS access for auto OTP verification, camera/gallery/contacts access and any other permissions required to enable certain functionalities within the mobile application.c. Information We Receive from Other SourcesWe may receive information about you if you use any of the other websites/apps we operate or the other services we provide. Such data may be shared internally and combined with data collected through use of the Online Platforms. We also work closely with select third parties including, for instance, subcontractors such as advertising networks, analytics providers, search information providers and may receive information about you from such sources. We collect non-personally identifiable information to track the total number of visitors to the Online Platforms in aggregate form and identify the type of internet web browser and operating system used by the visitor. This information allows us continuously to improve the Online Platforms and Services.

4. Express Consent:

You also specifically agree and consent to us and our group or affiliate companies collecting, storing, processing, transferring and sharing information (including Personal Information) related to you with third parties such as banks, non banking financial instituitions, prepaid instrument issuers, financial institutions, credit information companies, entities registered under applicable laws solely for the purpose of reviewing your profile and processing your transaction requests for the Services or for such other products/services offered by us or our group, affiliate or associates. In addition to the above, we identify and use your IP address to help diagnose problems with our server, resolve such problems and administer the Online Platforms. Your IP address is also used to help identify you and to gather broad demographic information. We may occasionally ask you to complete optional online surveys. These surveys may ask you for your contact information and demographic information including zip code, age, or income level. We use this information to tailor your experience at the Online Platforms, providing you with content that we think you might be interested in and to display content according to your preferences. We use your Personal Information to send you promotional emails, however, we will provide you the ability to opt-out of receiving such emails from us. If you opt out, the Company may still send you non-promotional emails, such as emails about the Services and your Account on the Online Platforms. Unless and until, you explicitly give your consent to us, to do so, we will not share your Personal Information with another user of the Online Platforms and vice versa.

5. User access of Personal Information

As a registered SPAC User, you can view and modify some of your Personal Information and your privacy preferences by accessing the “Account” section of the Online Platforms.

6. Use of Your Information

Our primary purpose in collecting Personal Information is to provide you with a secure, smooth, efficient, and customized experience. We may use your Personal Information for the following: to provide and improve the Services on the Online Platforms that you request;
to resolve disputes and troubleshoot problems;
to help promote a safe service on the Online Platforms and protect the security and integrity of the Online Platforms, the Services and the users;
collect money from you in relation to the Services,
inform you about online and offline offers, products, services, and updates;
customize your experience on the Online Platforms or share marketing material with you;
to detect, prevent and protect us from any errors, fraud and other criminal or prohibited activity on the Online Platforms;
enforce and inform about our terms and conditions;
to process and fulfil your request for Services or respond to your comments, and queries on the Online Platforms;
to contact you;
to allow our business partners and/or associates to present customised messages to you;
to communicate important notices or changes in the Services, use of the Online Platforms and the terms/policies which govern the relationship between you and the Company and with our affiliates for providing Services to you; and
for any other purpose after obtaining your consent at the time of collection.Further, we may use the data and Information collected/ stored as mentioned above for providing or improving our Services, improving user experience, risk checks, strengthening our security checks, for analysis and for offering you new features in the existing Services you are availing or offering altogether new product/ service which may be relevant for you. We collect and use some of your information in an aggregated form to compile statistical and demographic profiles for our business and marketing activities and to customise our Services to you.

7. Disclosure of information

Information security is critical to us and we will not share your Information with any other third parties except, and only to the extent necessary, after duly adhering to the confidentiality obligations consistent with this Privacy Policy: We may make your Personal Information and/or other Information available to our group entities/ affiliates to enable providing you Services through the Online Platforms. Please note that all information shared with our group entities or affiliates or made available to our group entities or affiliates will be governed by the terms of this Privacy Policy. We may also disclose your Personal Information to third party vendors, consultants, and other service providers who work for the Company, who are bound by contractual obligations to keep such personal information confidential and use it only for the purposes for which we disclose it to them. This disclosure may be required for us, for instance, to provide you access to our Services and process payments including validation of your bank accounts, to facilitate and assist our marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services. We do not disclose your Personal Information to third parties for their marketing and advertising purposes without your explicit consent. The SPAC may disclose your information, to the extent necessary: to comply with laws and to respond to lawful requests and legal process,
to protect the rights and property of the Company, our users, and others, including to enforce the terms, and
in an emergency to protect the personal safety and assets of the Company, the users, or any person.
In such an event SPAC is in no manner responsible for informing you or seeking your approval or consent. We and our group entities or affiliates (to the extent Personal Information is collected by them) may, in compliance with applicable laws, share/transfer/assign all of your Personal Information and other information with any other business entities, in the event of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of our business.

8. Security Practices

Information security is critical to us and we will not share your Information with any other third parties except, and only to the extent necessary, after duly adhering to the confidentiality obligations consistent with this Privacy Policy:We may make your Personal Information and/or other Information available to our group entities/ affiliates to enable providing you Services through the Online Platforms. Please note that all information shared with our group entities or affiliates or made available to our group entities or affiliates will be governed by the terms of this Privacy Policy.We may also disclose your Personal Information to third party vendors, consultants, and other service providers who work for the Company, who are bound by contractual obligations to keep such personal information confidential and use it only for the purposes for which we disclose it to them. This disclosure may be required for us, for instance, to provide you access to our Services and process payments including validation of your bank accounts, to facilitate and assist our marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services. We do not disclose your Personal Information to third parties for their marketing and advertising purposes without your explicit consent.The SPAC may disclose your information, to the extent necessary:to comply with laws and to respond to lawful requests and legal process,
to protect the rights and property of the Company, our users, and others, including to enforce the terms, and
in an emergency to protect the personal safety and assets of the Company, the users, or any person.In such an event SPAC is in no manner responsible for informing you or seeking your approval or consent. We and our group entities or affiliates (to the extent Personal Information is collected by them) may, in compliance with applicable laws, share/transfer/assign all of your Personal Information and other information with any other business entities, in the event of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of our business.

9. Data Retention

SPAC may, at its sole discretion, retain any information and/or data provided by you for as long as your Account is active, for resolution of disputes, for the purpose of investigations or ongoing prosecutions or in case of any suspicious/illegal transactions, for enforcement of any agreements, and/or as necessitated under applicable laws. The retention period may be extended in accordance with the applicable law. We make no warranties and shall not be liable regarding non-availability or non-retention of any information and/or data provided by you beyond the deletion of your Account.

10. Amendments & Updates to the Policy

SPAC reserve the right to amend this Privacy Policy from time to time to ensure that this Privacy Policy is consistent with any developments to the way, we use your Personal Information or any changes to the laws and regulations applicable to us. We will make available the updated Privacy Policy on the Online Platforms. You are encouraged to visit the Online Platforms from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. All communications, transactions and dealings with us shall be subject to the latest version of this Privacy Policy in force at the time.This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated.

11. Cookies

A cookie is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. We use cookie and tracking technology depending on the features offered. No Personal Information will be collected via cookies and other tracking technology; however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties.

12. Links to Other Sites

The procedures and practices set forth in this Privacy Policy describe the use and disclosure of information collected only through the Online Platforms. These Online Platforms may contain links to other websites. Any Personal Information about you collected whilst visiting such websites is not governed by this Privacy Policy. You are encouraged to exercise caution and review the privacy policies applicable to such websites before accessing them. You acknowledge that SPAC shall not be responsible for and has no control over the practices and content of any website accessed using the links contained on our Online Platforms.13. Grievance Officer

If you have any grievance with respect to the Online Platforms, please feel free to reach out to the grievance officer, the contact details of this officer have been provided below:Email: support@getspac.app