Privacy Policy

This Privacy Policy ("Policy") governs the manner in which SKPE Pvt Ltd (the "Company" or "We") collects, gains access to, uses, maintains, stores, transfers/shares and discloses information including personal or sensitive personal data or information of the users (each, a "User" or "You/you" or "Your/your" or "Customer") of various services rendered by the Company ("Services") either through the portal/website of the Company or through mobile applications (collectively referred to as "Platform"). Please note that the scope of this Policy is limited to the aforesaid information collected or received by the Company through your use of the Services. By using the Services, you are expressing your agreement to this Policy and the processing of your information, including your Personal Information and non-personal information, in the manner provided in this Policy. If you do not agree to these terms, please do not use the Services and do not provide the permissions when specifically asked by the Company.

All the terms and conditions/policies in respect of the Services provided by the Company (as set out in the Terms and Conditions or any other policies of the Company) are incorporated in this Policy by reference. The Policy seeks to comply with the provisions of the Information Technology Act, 2000 ("Act") and the Information Technology (Reasonable security practices, procedures and sensitive personal data or information) Rules, 2011 ("Rules").

What We Collect?

We may collect and/or gain access to and/or record certain information including personal information from or of a User in a variety of ways, including, but not limited to, when a User accesses and uses the Services and in connection with other activities, services, features or resources we make available on the Services. This information may relate to and include, but is not limited to, your name, date of birth, gender, father's name, mother's name, marital status, email address, address (including PIN code, city, state, residence type), phone number (including alternative mobile number, reference mobile number, reference person name), your unique device ID (persistent / non-persistent), photograph/selfie, your KYC details/documents, business details/documents (including business address), PAN number, GST details (including extracting GST from PAN or from GST number), hardware type, international mobile equipment identity ("IMEI"), the version of your operating system ("OS"), your device name, your email address (if connected to Facebook or Google), and your location (based on your Internet Protocol ("IP") address, including demographics such as latitude/longitude at various stages), applications installed or uninstalled by you through our mobile application, other applications installed on your device, foreground running apps/processes, SMS data, network information, user behaviour analysis, demographic information such as preferences and interests, Credit/Debit Card information for internet banking (we do not store card information on our servers), credit or affluence-related information or assessment/documents, your selected offers, bank statements (uploaded or via net banking), personal bank account numbers and bank account data/details including e-NACH, NEFT, IMPS, UPI ID details, and salary and income details. Users can always refuse to supply Personal Information; however, this may prevent them from engaging in certain Services-related activities.

What We Do With the Personal Information We Gather

We may use your Personal Information to:

• Administer the Services.
• Provide direct links to the Services for the User.
• Process transactions.
• Process installation.
• Send Users our newsletter.
• Develop, deliver, and improve our products, services, content, and advertising.
• Send important notices, such as communications about purchases/downloads and changes to our Policy.
• Carry out auditing, data analysis, and research to improve the Services.
• Troubleshoot and understand usage trends.
• Send notifications and alerts to Users.
• Market and promote the Services.
• Send transactional and other necessary information by SMS and other electronic modes.

Security

• We are committed to ensuring that a User's Personal Information is secure. We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of a User's Personal Information, username, password, transaction information, and data stored in our Services/eco-system.
• When a User uses Services and products offered by us, the Personal Information shared by that User is visible to other users and can be read, collected, or used by them. The User is responsible for the Personal Information they choose to submit in these instances — for example, if a User lists their name and email address in a blog/forum posting, that information is public. Users are requested to take care when using these features.

Retention of Personal Information

We will retain a User's Personal Information for the period necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.

Sharing Personal Information

We may use third-party service providers to help us operate our business and Services or administer activities on our behalf, such as sending out newsletters or surveys. We may share a User's Personal Information with these third parties for those limited purposes.

Third Party Websites

Users may find advertising or other content on the Services that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these sites and services and are not responsible for the practices employed by websites and services linked to or from our Services. These linked sites may have their own privacy policies and customer service policies, and browsing or interacting with them is subject to their own terms and policies.

How We Use Cookies

A cookie is a small file which asks permission to be placed on a User's desktop/laptop/mobile device's memory drive. Once the User agrees, the file is added and the cookie helps analyse web traffic. Cookies allow the Services to respond to the User as an individual, tailoring operations to the User's needs, likes and dislikes by gathering and remembering information about their preferences.

Cookies help us better understand a User's behaviour and tell us which parts of the Services Users have visited, helping us measure the effectiveness of our products and services. We treat information collected by cookies and other technologies as non-personal information; however, to the extent internet protocol (IP) addresses or similar identifiers are considered Personal Information by applicable law, we also treat these identifiers as Personal Information.

We use traffic log cookies to identify which pages are being used. This helps us analyse web page traffic and improve our services to tailor them to customer needs. We only use this information for statistical analysis, after which the data is removed from the system.

Overall, cookies help us provide Users with a better experience of SKPE's services by letting us monitor which pages Users find useful and which they do not. A cookie in no way gives us access to a User's desktop/laptop/mobile device or any information about the User other than the data they choose to share with us. Users can choose to accept or decline cookies — most browsers accept cookies automatically, but browser settings can usually be changed to decline them, though this may limit use of some Services.

Advertising

Advertisements appearing on SKPE's services may be delivered by advertising partners, who may set cookies. These cookies allow the ad server to recognise a User's computer each time it sends an online advertisement, compiling non-personal information to help deliver advertisements the User is more likely to find relevant. This Policy does not cover the use of cookies by any advertisers.

User Acceptance of These Terms

By using the Services, you agree that SKPE Pvt Ltd may collect, use, store, and share your Personal Information and non-personal information in the manner set out in this Policy. If you do not agree with these terms, please do not use the Services. Your continued use of the Services after any change or amendment to this Privacy Policy indicates your acknowledgement of such changes and your agreement to be bound by the terms and conditions of those changes.

• You may, at any time, revoke or withdraw the consent you have given us for the collection and use of your Personal Information and non-personal information by submitting a request to Support@skpenetwork.com. However, this right is limited in some situations, such as where we are legally or otherwise bound to process or retain your Personal Information.
• Please note that revoking consent may affect our ability to process or enable your Personal Information and may lead to discontinuation of the Services for which it was being used, at our sole discretion. You do not have an unqualified right under applicable law to deletion of your Personal Information and non-personal information.

Disclosure of Data / Information

SKPE will not share any personal or sensitive data with any external organisation unless necessary to provide the Services (to a User or business associate), to complete a legitimate transaction, or for reporting required under applicable law or agreed terms and conditions. SKPE may disclose information about a User and/or business associate if directed by a court, regulatory, statutory, or other authority, and shall promptly seek consent from the User and/or business associate, providing sufficient details of the relevant order or process, before disclosing such information.

SKPE Shall Access, Preserve and Share Your Information

• With regulators, law enforcement, or others in response to a legal request (e.g. a search warrant, court order, or subpoena) if we have a good-faith belief that the law requires us to do so — including requests from jurisdictions in India or abroad, where the response is required by law, affects users in that jurisdiction, and is consistent with recognised Indian standards.
• When we have a good-faith belief it is necessary to detect, prevent, and address fraud, unauthorised use of the products, violation of our Terms or Policies, or other harmful or illegal activity; to protect ourselves, the User, or others, including as part of an investigation or regulatory enquiry; or to prevent death or imminent bodily harm. For example, we may exchange information with third-party partners about the reliability of your account to prevent fraud and abuse.

Information we receive about you, including financial transaction data, can be accessed and preserved for an extended period when it is subject to a legal request or obligation, a governmental investigation, or an investigation of possible violations of our Terms or Policies, or otherwise to prevent harm.

Observance of Reasonable Security Practices

SKPE shall take all reasonable precautions to maintain the confidentiality of Personal Information/data pertaining to its Users and business associates, by imparting proper training to its employees and providing restricted access to persons who require it strictly on a need-to-know basis.

Links to Other Websites

Our website contains links to other websites. When a User clicks one of these links, they enter another website for which SKPE takes no responsibility. SKPE encourages Users to read the privacy statements/terms and conditions of all such websites, as their policies may be materially different from this Privacy Policy. Users are solely responsible for maintaining the secrecy of their passwords and other membership account information.

New Owner

If the ownership or control of SKPE, or all or part of our products, services, or their assets changes, we may transfer a User's information to the new owner.

Updates to This Privacy Policy

SKPE may change its data privacy practices and update this Privacy Policy as and when the need arises, and the updated version shall be made available on the website. Users and business associates are requested to check this page periodically for updates.