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This Privacy Policy is incorporated by reference into ChangeJar /Jar Terms of Service (the “Terms”).
Website myjar.app and/or the mobile application ‘Jar’ (collectively referred to as the “Platform”) is owned and operated by Changejar Technologies Private Limited, a private limited company having its registered office at No. 752, 18th main, 6th block, 5th cross Koramangala Bangalore-560095, which shall include its affiliates and group entities, together referred to as “Company”, “We”, “Us” or “Our”.
This Privacy Policy applies to all the Users whose Personal Information has been processed by Us in the course of our business, mobile applications, forums, blogs, and other online or offline offerings
We respect your privacy and hence handle your personal data with the utmost care and confidentiality.
By visiting the Platform, You (“You” or “Your”), accept and agree to be bound by the terms and conditions of this privacy policy (“Privacy Policy”). This Privacy Policy is incorporated into and subject to the terms of use of the Platform(“Terms”) and shall be read harmoniously and in conjunction with the Terms.
We respect your privacy and hence handle your personal data with the utmost care and confidentiality. Please read the Privacy Policy carefully prior to using or registering on the Platform or accessing/availing the services on the Platform inter alia in relation to purchase/sale/transfer of Digital Gold from a brand named “Safe Gold” operated and managed by “Digital Gold India Private Limited”(hereinafter referred as “Safe Gold”) a company incorporated under the laws of India (“Services”).
This Privacy Policy specifies the manner in which personal data and other information is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company. This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party (excluding the Company or its affiliates set out in paragraph 4 below) through the Platform, and any Third-Party Sites that You access or use in connection with the services offered on the Platform.
By visiting the Platform, You (“You” or “Your”), accept and agree to be bound by the terms and conditions of this privacy policy (“Privacy Policy”). This Privacy Policy is incorporated into and subject to the terms of use of the Platform(“Terms”) and shall be read harmoniously and in conjunction with the Terms.
It is important that you read this privacy notice together with any other privacy policy or fair processing notice we may provide on specific occasions or when we are collecting or processing Personal Information about You so that You are fully aware of how and why we are using Your Personal Information . Additionally, we also recommend you to read the terms and privacy policy of Safe Gold which can be accessed at https://www.safegold.com/privacy-policy
This privacy notice supplements the other notices/policy and is not intended to supersede them.
To provide you the services, we collect, use and process your personal information including your sensitive information. The types of personal information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with the Company and the requirements of applicable law.
In addition to the information that you provide us directly, we also collect information that You provide to Safe Gold and other third parties for providing Services and for technology support like application programming interfaces (APIs) and embeds to make that information available in our database. 2. We may retrieve from Your records available with third party including from Know Your Customer (KYC) Registration Agency (KRA) such as name, KYC details, KYC status, father’s name, occupation, address details and related documents.;
i) Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Services. This includes technologies that allow you access to our Services; that are required to identify irregular site behaviour, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as, product information, saved search, or similar functions.
ii) Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our Services, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Services’ content, applications, services, or tools;
iii) Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Services;
iv) Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Services or on Third Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on ourPlatform, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
The information collected allows Us to provide the Services and features on the Platform that most likely meet Your needs, and to customize the Platform to make Your experience safer and easier.
However, You can browse the Platform without telling Us who You are or revealing any Personal Information about Yourself. In such a case, we will only collect and store the Non – Personal Information. Once You give us your Personal Information, You are not anonymous to Us. Wherever possible, while providing the information to Us, We indicate which fields are mandatory and which fields are optional for You. You always have the option to not provide the Personal Information to Us through the Platform by choosing to not use a particular Service or feature being provided by Us on the Platform, which requires You to provide such information. We may automatically track certain information about You based upon Your behaviour on the Platform. We use this information to do internal research on Your demographics, interests, and behaviour to better understand, protect and serve You. This information is compiled and analysed by the Company on an aggregated basis and not individually, in a manner that does not specifically identify You.
We use the Personal Information and other non-Personal Information, for the following:
Further to the above, You may also choose to provide Your explicit consent to connect/integrate Your email account(s) and/or registered mobile number with Your account on the Platform by clicking on the authentication email/message sent by the Company on Your registered email address and/or registered mobile number. You will be expressly asked in each case whether You want to connect Your email address and/or Your registered mobile number with Your account on the Platform. You can also choose to enable Our access to one or more of Your email accounts by connecting such account(s) with Your account on the Platform. Once connected, the Platform will securely access and analyze the emails and passwords and in case of registered mobile number, Your text messages, if any to populate and track Your investments details and history including those made through the account on the Platform and consolidate them at one place. Such data obtained by this integration will be used by the Company solely for providing the Services and improving Your experience of the features of the Platform and to consolidate your investment details and history. The Company hereby agrees and acknowledges that it shall not use or transfer any data or information received from the integration of the email addresses with the account on the Platform to third parties for serving ads, including retargeting, personalized, or interest-based advertising. However, we may share the same with Safe Gold and its affiliates for providing you the Services.
You also specifically agree and consent to Us for collecting, storing, processing, transferring and sharing information (including Personal Information) related to You with third parties solely for the purpose of processing your transaction requests for the Services. 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 Platform and vice versa.
We may make Your Personal Information and/or other Non-Personal Information available to Our partners, collaborators including Safe Gold and its affiliates to enable them to provide Services through the Platform to You. Please note that all information shared with our partners, collaborators and affiliates or made available to our partners, collaborators 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.
You also specifically agree and consent to Us for transferring and sharing your sensitive personal information (including your biometric data, financial information, passwords) related to You with Our partners, collaborators including Safe Gold and its affiliates, third parties and other service providers solely for the legitimate purpose of proving you the Services.
We do not disclose Your Personal Information to third parties for their marketing and advertising purposes without Your explicit consent.
The Company may disclose Your information, to the extent necessary:
Our Platform may link You to other third-party Platforms (“Third – Party Sites”) that may collect Your Personal Information including Your IP address, browser specification, or operating system. The Company is not in any manner responsible for the security of such information or their privacy practices or content of those 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 Privacy 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. We use third-party advertising companies to serve ads when You visit the Platform. These companies may use information (not including Your name, address, email address, or telephone number) about Your visits to the Platform and Third-Party Sites in order to provide advertisements about goods and services of interest to You. You agree and acknowledge that We are not liable for the information published in search results or by any Third-Party Sites.
Our Platform has reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration of the information in compliance with applicable laws. Further, whenever You change or access Your account on the Platform or any information relating to it, We offer the use of a secure server. We cannot however ensure or warrant the security of any information You transmit to the Company or guarantee that Your Personal Information and/or other Non-Personal Information provided for availing the Services or Platform may not be accessed, disclosed, altered or destroyed by a breach of any of Our security measures and safeguards.
It is further clarified that You have and so long as You access and/or use the Platform (directly or indirectly) the obligation to ensure that You shall at all times, take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information. When payment information is being transmitted on or through the Platform, it will be protected by encryption technology. You expressly consent to the sharing of Your information with third party service providers, including payment gateways, to process payments and manage your payment-related information. Hence, the Company cannot guarantee that transmissions of Your payment-related information or Personal Information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by the Company or the Company’s third-party service providers. The Company assumes no liability or responsibility for disclosure of Your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control. You play an important role in keeping Your personal information secure. You shall not share Your Personal Information or other security information for Your account with anyone. The Company has undertaken reasonable measures to protect Your rights of privacy with respect to Your usage of the Platform controlled by Us and Our Services. However, We shall not be liable for any unauthorized or unlawful disclosures of Your personal information made by any third parties who are not subject to Our control.
We collect and store your data and Personal Information in AWS cloud as you use services and will retain the data for as long as necessary to fulfil the purposes for which it was obtained. Processed and non-identifiable data, however, will be perpetually stored.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Company is merely providing a distributor platform of Safe Gold that facilitate transaction of sale and investment for Users and will not be liable in any manner with respect to the products/ services allotted to You. You hereby agree and acknowledge that the data and information provided on the Platform does not constitute advice of any nature whatsoever and shall not be relied upon by You while making investment decisions and You shall be solely responsible for any investment decisions and for the purchase of any mutual funds on the Platform. In no event shall the Company be liable to You for any loss or damage that may cause or arise from or in relation to these Terms of Use and/or due to use of this Platform or due to investments made using this Platform. As part of the Platform Services provided to You, after availing such services, You agree to provide honest feedback/review about the concerned Platform Service, if required by the Company.
8.YOUR PRIVACY RIGHTS
Your Consent: By visiting the Platform or setting up/creating an account on the Platform for availing the Services on the Platform at such time, You signify Your acceptance to the provisions of the Privacy Policy. You may choose to withdraw Your consent provided hereunder at any point in time. Such withdrawal of consent must be sent in writing to info@changejar.in. In case You do not provide Your consent or later withdraw Your consent, we request you not to access the Platform and/or use the Services and also reserve the right to not provide You any Services through the Platform. In such a scenario, the Company may delete Your information (Personal or otherwise) or de-identify it so that it is anonymous and not attributable to You. However, please note that Company reserves the right to refuse any request to exercise such rights to the extent permitted by applicable law.
9. CHANGES TO PRIVACY POLICY
We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time, without specifically notifying You of such changes. Any changes or updates will be effective immediately. You should review this Privacy Policy regularly for changes. Your acceptance of the amended Privacy Policy shall signify Your consent to such changes and agreement to be legally bound by the same.
10. GRIEVANCE OFFICER
If You have any privacy concerns, please feel free to reach out to the grievance officer, the name and contact details of this Officer have been provided below:
Name: Mr. Pankaj Parihar
Email: grievance-officer@changejar.in
He shall try to acknowledge the complaint within twenty-four hours and dispose of such complaint within a period of fifteen days from the date of receipt of complaint.
Effective as on 22nd April 2022
Registered Office address: No 752, 18th main,6th block,5th cross Koramangala Bangalore -560095.
1. INFORMATION WE COLLECT
1.1 Sensitive Data and Personal Information: In general, We may collect Personal Information, including Sensitive Data.
“Personal Information” means individually identifiable information that directly or indirectly, in combination with other information would allow the identification of a specific living person.
“Sensitive Data” means Your Personal Information such as financial information such as bank account details and/ or any other payment instrument details, sexual orientation, any details that may have been voluntarily provided by You and any of the information received under above clauses by Us in connection with availing the Services.
By providing Personal Information (including Sensitive Data) to us, you consent to the collection, usage, and disclosure of Personal Information (including Sensitive Data), as permitted by applicable laws. By using the Services, you are authorizing us to gather, parse data and retain basic data which are related to the provision of the Services.
1.2 Personal Information: We may collect and process your Personal Information, including but not limited to the following:
1.2.1 Information provided by you at the time of registration such as your name, address, email ID, phone number, bank account details, financial information, unique identifiers, and preferences information including favourites and history;
1.2.2 Information that you provide to us directly via email and/ or electronic communication;
1.2.3 Your bank account statement provided by you through the upload feature during the onboarding process on Jar Platform to assess your creditworthiness;
1.2.4 Your live selfie for your identity check and verification with your KYC documents. The image captured through this selfie may be shared with third party for the purpose mentioned in Clause 3.3 herein;
1.2.5 Information that you provide to us over telephone. We may make and keep a record of such information shared by you;
1.2.6 Information that you provide to us in physical form whether sent through post and / or courier and / or handed over to our representatives in person;
1.2.7 Any other additional information required to be provided via email/ electronic communication/ telephone/ post/ courier after your registration; and
1.2.8 Hardware model, operating system and versions and identifiers like IMEI number and serial number of your primary device used for availing Services.
1.2.9 Information from other sources.
1.3 Domain Name and IP Address: We may collect your domain name which is linked to every computer/ mobile device connected to the internet and a set of numbers that serve as that computer’s Internet Protocol or “IP” address. When you request a page from any page within the Website, our web servers automatically recognize your domain name and IP address. The domain name and IP address does not reveal any further information about you other than the IP address from which you have accessed the Website.
1.4 Cookies: If enabled, we may place cookies on your machine that store small amounts of data on your computer about your visit to any of the pages of this website. Cookies can identify the pages that are being viewed and this can assist us in tracking which of our features appeal the most to you and what content you may have viewed on past visits.
We use cookies on our website in order to personalize our service to you. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. Unless you have adjusted your browser setting to refuse cookies, our system will issue cookies when you log on to the website.
1.5 SMS: We do not collect, read, store or share with third parties your personal SMS, other than the SMS pertaining to your financial transactions solely to assist our lending partners in assessing your credit risk.
1.6 Phone: We shall take one-time access of certain features of your mobile phone to facilitate on-boarding on the platform and KYC verification:
1.7 Biometric Data: No Personal Information of yours containing biometric data will be collected or stored by Jar unless permitted by extant statutory guidelines.
2. HOW WE USE INFORMATION WE COLLECT
Our primary goal in collecting the information is to provide you a platform to render our Services. We may use the personal information provided by you for one or more of the following:
a. To help provide you the Services;
b. To observe, improve and administer the quality of Services;
c. To analyze how the platform is used and diagnose technical problems;
d. Remember the basic information provided by you for effective access;
e. To confirm your identity in order to determine your eligibility to use the platform and avail the Services
f. To notify you about any changes to the Website;
g. To enable us to comply with our legal and regulatory obligations;
h. For the purpose of sending administrative notices, Service-related alerts and other similar communication with a view to optimizing the efficiency of the Website;
i. Doing market research, troubleshooting, protection against error, project planning, fraud and other criminal activity; and
j. To enforce our Terms of Use.
3. DISCLOSURE OF INFORMATION
3.1 We do not publish your Sensitive Data provided by you.
3.2 We will treat your Personal Information strictly confidential. We will not disclose your Personal Information to anyone, except in the following cases:
3.3 Sharing: You hereby consent to sharing your Personal information with credit information companies, analytics, technical partners, payment facilitators, commercial partners, lending partners, etc for purposes including but not limited to providing and monitoring Our Services, onboarding process on the Jar Platform, assessing the creditworthiness, KYC verification, fraud prevention and risk evaluation. We may share aggregated demographic information with our partners or affiliates. This is not linked to any personal information that can identify an individual person. We will not be liable for transfer of any personal identification information resulting from loss or distribution of data, the delineation or corruption of media storage, power failures, natural phenomena, riots, act(s) of vandalism, sabotage, terrorism or any other event beyond our control. Further, our Privacy Policy does not cover the use of cookies by its partners and affiliates since we do not have access or control over such cookies.
3.4. Consulting: We may partner with other parties to provide specific portions of the Services, if required. When you sign-up for the Services, we may share some of your Personal Information (including phone number registered or to be registered with Jar) and Sensitive data to the extent necessary for the third party to provide these Services. Our contractual arrangements with such third parties restrict these parties from using personally identifiable information except for the explicit purpose of assisting in the provision of these Services.
3.5. Promotional Offers: We may send you offers, which may be on behalf of other businesses. If you do not want to receive such offers, you may request us to adjust your preferences.
4. CHANGE OF INFORMATION
If your Personal Information or Sensitive Data changes, you may correct, delete inaccuracies, or amend information by reaching out to us at ID: lending.support@changejar.in. We may request you to provide any additional information or documents as may be necessary to verify the changes requested by you.
5. SECURITY OF INFORMATION
5.1 We take the security of your information very seriously. To this end, we use several security techniques including secure servers at India, firewalls, and encryptions, as well as physical safeguard of the locations where the data are stored. We have in place appropriate administrative, technical, physical safeguards and security measures to protect the personal data you provide to us against accidental, unauthorized, or unlawful loss, destruction, damage, alteration, access, disclosure or use and any other unlawful forms of processing. When we collect data, we collect your personal details on a secure server. We use firewalls on our servers. Whilst we are unable to guarantee 100% security, this makes it hard for a hacker to decrypt your details. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage and disclosure of your information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you. You are responsible for protecting against unauthorized access to your password and to your computer.
5.2 The information that is collected from you may be transferred to, stored, and processed at any destination as permitted under applicable law. By submitting information to us, you agree to this transfer, storing and/ or processing. We will take such steps as we consider reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.
5.3 In using the Services, you accept the inherent security implications of data transmission over the internet. Therefore, the use of the Website will be at your own risk, and we assume no liability for any disclosure of information due to errors in transmission, unauthorised third party access or other acts of third parties, or acts or omissions beyond its reasonable control and you agree not to hold us responsible for any breach of security.
5.4 In the event we become aware of any breach of the security of your information, we will promptly notify you and take appropriate action to the best of its ability to remedy such a breach.
6. DATA RETENTION
You may request us to delete your information or revoke the consent to access or opt out of processing your application by submitting a request for account deletion through the Jar mobile app via the profile section. On submitting a request to delete Your account, you confirm/understand that:
1. You have no outstanding credit facility availed on the Jar platform.
2. You have no pending or potential grievances in relation to any of your previous dealings with Us.
3. Your account will be permanently deleted. We will not be able to reactivate your account.
4. You will receive no further communications from Jar.
You however understand that We will be required to or retain, and accordingly use and disclose any specific data if required by law, rule, regulation, law, enforcement, governmental official, legal, or regulatory authorities and / or to such other statutory bodies who have appropriate authorisation or for the purposes of completing any legal obligations or for audit requirements. We will not retain your Personal Information(including sensitive personal data) for longer than is required for the purpose for which the information may lawfully be used.
7. NOTIFICATION OF CHANGES
We may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way we treat your Personal Information, or in the Privacy Policy document itself, we will display a notice on the Website or send you an email informing you of such changes, so that you may review the changed terms prior to continuing to use the Website and our Services.
Using the Company’s Services or accessing the Website after a notice of changes has been sent to you or published on the Website will constitute your consent to the changed terms.
It is very important that any Personal Information we hold/pass on to our lending partners about you is up to date and correct. Please inform us at lending.support@changejar.in for any changes to your Personal Information.
8. ADDRESS FOR PRIVACY RELATED QUESTIONS
To offer optimum support to our customers and to address complaints and grievances in the most effective manner, we have set out the process for registering and getting the complaint addressed.
In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below.
Name: Mr. Pankaj Parihar
Address: No.752 Vasantham Building, 18th main, 6th block, 5th cross Koramangala Bangalore - 560095
Email ID: grievance-officer@changejar.in