Date Updated: [15 January, 2023]
The App/Site (i) provides an online digital ledger book / record book wherein the Users, can record their ledger entries with their respective customers and (ii) also allows Users to generate a payment link which can be sent it to their respective customers and the customers could use the payment link and make the payment of the amount to the Users in settlement of their obligations towards the Users (collectively, “Services”). Please note that ‘Services’ would include any other future services we may provide or propose to provide.
As we update, improve and expand the Linkup App Service, this Policy may change, so please refer back to it periodically. By accessing the Site, App or otherwise using the Linkup App Services, you consent to the collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the services that we offer.
We respect the privacy of the users of the Linkup App Services (“Users” or “you”) and are committed to reasonably protect it in all respects. The information about the User as collected by us is: (a) information supplied by Users and (b) information automatically tracked while using a mobile device having Linkup App Services enabled (collectively referred to as “Information”). By using Linkup App Services, you agree to this Policy. If you do not agree with any term in this Policy, please do not use / avail of the Linkup App Services.
To avail certain Services on the Linkup App, Users are required to provide certain personal information for the registration process which may include: a) their name, b) email address, c) phone number, d) business entity information, (e) account number of the Users, (f) KYC details and any other such information as required. The Information as supplied by the Users enables us to provide the Services and improve the Linkup App Services and provide you the most user-friendly experience. In some cases / provision of certain service(s) or utility(ies), we may require your contact address as well. Further, upon downloading the App, Users are requested to share access to their contact list (as stored on their mobile device on which the App is downloaded), so as to enable the User to share payment/credit updates with his customers (who might be or might not be Users). In an attempt to improve our Services, we may, from time to time, collect any information (other than what is mentioned above) from Users through App / Site. You may be assured that we do not share this data with any third party except in accordance with the terms of this Policy.
We may access a user's inventory of installed apps and treat this data as personal or sensitive data subject to this Policy, secure transmission, and prominent disclosure requirements of User.
All Information is service dependent and we may use the Information to provide the Services, maintain, protect, and improve the Linkup App Services, and for developing new services.
We may also use your email address and phone number without further consent for marketing, non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about updates to Linkup App Services, billing, etc.).
Any Information provided by you will not be considered as personal information if it is freely available and/or accessible in the public domain or is not deemed as a personal information under the applicable law. Further, any reviews, comments, messages, blogs posted/uploaded/conveyed/communicated by Users on the public sections of the Site or an application store (like the App Store or Play Store) becomes published content and is not considered as personal information which is subject to this Policy.
In case you choose to decline to submit Information on the Linkup App/Site, we may not be able to provide certain services on the App/Site to you. We will make reasonable efforts to notify you of the same at the appropriate time. In any case, we will not be liable and or responsible for the denial of certain services to you for due to not receiving necessary Information from you.
When you register with the Linkup App Services, we may (at our discretion) contact you from time to time about updation of your Information.
We store all your credit/payment records in a cloud-based environment using the services of third party infrastructure service providers.
We store the contact information of your customers. We also keep a log of all the credit/payment related communication to the customers.
Demographic and Related Information:
We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track the User behaviour on Site.
Log File Information:
Our Servers automatically collect limited Information about your device's connection to the internet, including your IP address, when you visit our Site or use the App. We automatically receive and log Information from the App and/or your browser including but not limited to IP address, your device or computer's name, and your operating system, We may also collect log Information from your device, including but not limited to your location, IP address, your device's name, device's serial number or unique identification number (e.g. UDID on your iOS device, Android ID or ADID on your Android Device), your device operating system, browser type and version, CPU speed, and connection speed etc.
The Information (including personal information) collected may be shared with our affiliates, and group companies to the extent required for our internal business and/or administrative purposes and/or general corporate operations and to any third party service providers including marketing partners, and the User hereby consents to the same. We will take reasonable steps to ensure that these third-party service providers are obligated to protect your personal information and are also subject to appropriate confidentiality/non-disclosure obligations and they comply with the applicable provisions of the data protection laws. These entities, with whom we share the Information, may market to you as a result of such sharing unless you explicitly opt-out.
The User explicitly consents that we may have access to your SMS, contacts in your directory, location and device information and we may request you to provide your PAN and Know-Your-Customer (KYC) details to check your eligibility for certain products/services including but not limited to credit and payment products, etc., to enhance your experience and provide you access to the services being offered by us, our affiliates or other third party service providers (including lenders).
By using the Linkup App Services and providing information to us, Users agree and consent to the disclosure, transfer, storage, and processing of the personal information (including the sensitive personal information) by us in India and / or in other countries to its affiliates, group companies and third parties. While our primary motive is to protect the disclosure of personal information (except in accordance with the provisions of this Policy) of Users, Users may note that countries where their Information may be stored, may not have data protection laws similar to the countries where they are located.
We don’t collect, read or store your personal SMS from your inbox. We collect and monitor only financial SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various bank accounts that you may be holding, cash flow patterns, description and amount of the transactions undertaken by you as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis. This process will enable you to take financial facilities from the regulated financial entities available on the Platform. This Financial SMS data also includes your historical data.
When Users use the Site (or any of its sub sites) / App, we make good faith efforts to provide Users, as and when requested by Users, with access to their Information and shall further ensure that any personal information or sensitive personal data or other Information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal Information or sensitive personal data or Information to be retained by law or for legitimate business purposes. We ask individual Users to identify themselves and the Information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning Information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide Information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your Information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
From time to time, we take backup of your data on Linkup App on our cloud database. This is done for the purpose of enabling Users to get their data back in case their phone's data becomes unusable, or phone gets lost, or the User moves to a new phone device. We also use this backup to provide useful insights and information related to their spends such as weekly spends in a month, insights related to spend behaviour, etc., and to provide information related to User spends, patterns and User data in the form of aggregated and anonymized statistics on data such as User spends by category, date, time, bank balances, etc.
We shall keep User’s Information in our records till the period of time where we can potentially offer the Linkup App Services to the Users. After such period of time where Linkup App Services are no more relevant to a User, we remove all the Information pertaining to a particular User from our records.
We take appropriate security measures to protect against unauthorized access to or alteration, disclosure or destruction of data including accidental or intentional manipulation, loss from access by unauthorised parties. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All Information gathered on the Linkup App is securely stored within the controlled database. Access to the servers is password-protected and is strictly limited.
Our security measures are regularly reviewed and updated to reflect technological developments. Regardless of where your personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal information is kept secure, however, please understand that no transmission of data over the internet or any other public network can be guaranteed to be 100% (one hundred percent) secure.
We seek to ensure compliance with the requirements of the applicable data protection laws to ensure the protection and preservation of the User’s privacy and personal Information. We have physical, electronic, and procedural safeguards that comply with the laws prevalent in specific jurisdiction to protect User’s Personal Information. By accepting the terms of this Policy, you agree that the standards and practices being implemented by us, are reasonable and sufficient for the protection of your personal information.
We will contact you regarding any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information to you via email or any other feasible manner in the most expedient time possible and without unreasonable delay, insofar as consistent with the legitimate needs of law enforcement and will undertake all measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
For example, we use your information where we need the Personal Information to perform the contract with you (for example, to provide the Platform or our services to you) so as to:
We will use your Personal Information with your explicit consent as follows:
Or otherwise whenever the law requires us to get your permission or where we have stated we may seek your permission in this Privacy Notice. In some contexts, we use your Personal Information where we have a legal obligation to do so or to protect your vital interests or those of another person:
When you access or use the Services or send any data, query, request or communication to us via our Support email, you understand that you are communicating with us electronically, and that we may respond via electronic means from us, such as by email.
The App has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third-party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data. Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need- to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data. Furthermore, our registered third party service provider provides hosting security – they use industry- leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.
A User can revoke his consent to the processing of his personal information at any time with effect for the future. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal information where such collection, use and disclose without consent is permitted or required under applicable laws.
All the Linkup App Services are currently provided and regulated by Noledger India Private Limited and therefore Noledger India Private Limited is responsible for the collection, storage and processing of personal information of the Users.
In the event you have any grievance relating to the processing of Information provided by you, you may contact our Grievance Officer at firstname.lastname@example.org or write to us at the following address:
NOLEDGER INDIA PRIVATE LIMITED OFFICE
GROUND FLOOR, PLOT NO-10, BAMBAWADI B/S KRISHNA MARKET,
Surat, GUJARAT, INDIA - 395004
In case any personal information is shared by you with us, which is not requested by us during registration, (whether mandatorily or optionally), we will not be liable for any information security breach or disclosure in relation to such information. If you have any questions regarding this Policy or the protection of your personal information, please contact our data protection officer/grievance officer.