PRIVACY POLICY

This Privacy Policy (this “Policy”) describes Acko General Insurance Limited’s policies and procedures for collection, use, storage, disclosure, and protection of any personal information, including any sensitive personal information, provided by you or collected by us, for accessing or using Platform and/or availing the Services or any products offered by us.

BY VOLUNTARILY PROVIDING US OR ALLOWING US TO ACCESS THE PERSONAL INFORMATION (INCLUDING ANY SENSITIVE PERSONAL INFORMATION) OR USING THE PLATFORM, YOU ARE CONSENTING TO USE OF IT IN ACCORDANCE WITH THIS POLICY. YOU FURTHER WARRANT AND CONFIRM THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY AND YOU PROVIDE YOUR UNEQUIVOCAL CONSENT TO ALLOW US TO COLLECT, RETAIN, SHARE, PROCESS AND STORE YOUR PERSONAL AND SENSITIVE PERSONAL INFORMATION AS PER THIS POLICY. 

IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, PLEASE DO NOT PROCEED FURTHER TO USE/ ACCESS THIS PLATFORM OR AVAIL ANY SERVICE. 

THIS POLICY DOES NOT APPLY TO THIRD-PARTY PLATFORMS THAT ARE CONNECTED VIA LINKS TO THE PLATFORM.

IF YOU DO NOT PROVIDE US PERSONAL INFORMATION OR WITHDRAW THE CONSENT FOR ANY OF YOUR PERSONAL INFORMATION AT ANY POINT IN TIME, WE SHALL HAVE THE OPTION NOT TO PROVIDE THE BENEFITS FOR THE PURPOSE OF WHICH THE SAID PERSONAL INFORMATION WAS PROVIDED / SOUGHT INCLUDING BUT NOT LIMITED TO REFUSING TO OFFER OUR PLATFORM OR SERVICE OR ANY PART THEREOF TO YOU. 

PLEASE FURTHER NOTE THAT WITHDRAWAL OF CONSENT BY YOU WILL NOT DIMINISH AND/OR AFFECT OUR RIGHTS AND/OR OBLIGATIONS UNDER THE APPLICABLE LAWS. ACCORDINGLY, YOU UNDERSTAND AND AGREE THAT WE WILL CONTINUE TO COLLECT, USE, PROCESS, AND STORE YOUR PERSONAL DATA AS PER THE REQUIREMENTS UNDER THE APPLICABLE LAWS, INCLUDING ANY SPECIFIC REQUIREMENTS PRESCRIBED BY THE IRDAI.

THIS POLICY HAS BEEN ADOPTED IN ACCORDANCE WITH THE INFORMATION TECHNOLOGY ACT, 2000 AND THE APPLICABLE DATA PROTECTION RULES AND REGULATIONS OF INDIA.

THIS POLICY ONLY APPLIES TO OUR USE, STORAGE, SHARING AND RETENTION OF YOUR PERSONAL DATA / INFORMATION. ANY NON-PERSONAL DATA OR INFORMATION PROVIDED BY YOU OR COLLECTED BY US IS OUT OF THE SCOPE OF THIS POLICY. NON-PERSONAL INFORMATION SHALL BE USED, SHARED, STORED AND/OR PROCESSED BY US AS PER OUR SOLE DISCRETION, SUBJECT ALWAYS TO APPLICABLE LAWS (IF ANY). FOR SAKE OF CLARITY, NON-PERSONNEL INFORMATION/ DATA IS SUCH INFORMATION OR DATA WHICH DOES NOT DIRECTLY IDENTIFY YOU OR IS AGGREGATED OR DE-PERSONALIZED AND/OR USING WHICH THE SPECIFIC IDENTITY OF AN INDIVIDUAL CANNOT BE ESTABLISHED. 

A. PERSONAL INFORMATION PROVIDED BY YOU AND/OR COLLECTED BY US: 

We will use the personal information, which includes any sensitive personal information / data, provided by you only in accordance with the purposes described in the applicable laws and/or this Policy. 

Except as provided herein or provided by you at the time of submission of the Application Form or signing of any policy / document or availing any service on the Platform or creating Your Account or making a request for claims, or otherwise clearly disclosed to you at the time of collection, we do not solicit any sensitive personal information about you. However, if you share such sensitive or personal information with us voluntarily, we will not be liable for any actions, claims, costs, expenses or other liabilities that may arise as a consequence of any unauthorized use or misuse of such personal information. Any personal information including your sensitive personal information provided by you on the Platform, will be deemed as an authorisation given by you to us to use, store, process and share such personal information for the purpose as stated out on the Platform, the applicable laws and this Policy. 

During your use of Platform, you may provide and/or we may collect and process such personal information from you, including but not limited to the below:

Ⅰ. Personal Information provided by You:

a) You are required to provide true, current and correct information to use the Service or access the Platform. You may provide the personal information to us:

ⅰ. by filling in application forms or signing-up for an account on the Platform or completing the Know-Your-Customer (“KYC”) or at the time of the on-boarding process or for availing any service on the Platform or during the claims / payout process. This may include contact information such as name, email address, mailing address, phone number, KYC documents like Voter ID, PAN, Driving License, policy details, etc.

ⅱ. voluntarily, when you call or write directly to us (including by e-mail, feedback and/or surveys); 

b) You may be required to provide further information to us for the purposes of issuance of policies and processing of refunds, claims, payouts, etc. Such additional information may include (without limitation) your health and lifestyle related data, bank statements, loan statement/s, salary and income statements, access to your camera including photos, and/or location, as prompted on the relevant page / disclosed at the time of collection. You may also be required to provide this information to us via physical documents, e-mail or other digital and offline methods, including granting us access rights on your device.

c) All information, documents, undertakings and data provided by you should be true, current and correct. 

d) You agree to provide current, true, latest and correct information and documents at any and all times, including for KYC or other purposes. The said KYC details and other documents may be used by Us to perform KYC, health or other checks and extend the services to you, as further detailed in this Policy.

e) You also consent to the use, disclosure and sharing of the personal information about you or with respect to co-beneficiaries, beneficiary / nominee (whether collected by Us or received from third parties or provided by you), including but not limited to information about you / co-applicants health, physical attributes, medical history, and lifestyle, etc. by Us. This will help you avoid repeat queries/tests, and help you avail the additional products, services or other new offerings as per the terms of this Privacy Policy.

f) In the event of any changes to any personal information or KYC documents or health / lifestyle information in the KYC or other documents (as the case may be), you will promptly notify us via email and/or update the details under Your Account section immediately.

Ⅱ. Personal Information Collected from Third Parties:

a) We may also be working closely with third parties (including, for example, business partners, partner banks and financial institutions, technical sub-contractors, analytics providers, underwriting agents, surveyors, etc.) and may lawfully receive information about you from such sources including our affiliates and/or group companies. Such personal data may be shared internally and combined with data provided by you, or collected on the Platform, or during provisioning of the Services to you. 

b) We may also use the content you have shared publicly, including on third party platforms or applications including any social media channel, to promote our Services and/or Our Platform and/or our affiliates, or their services / platform (including by quoting your content, reviews and/ or recommendations, or displaying screenshots of your content, reviews and/ or recommendations).

Ⅲ. Personal Information Collected by Us: 

a) Our Platform collects user account data which includes both personal (including sensitive personal information) and non-personal data/information, including but not limited to the email address, IP address, name to log in to the Platform. This information is required as part of the registration / creation of Your Account on the Platform, on-boarding process to provide our Service, and of processing your policies including refunds, claims, pay-outs, etc, and it is also used to auto populate relevant fields during your use of the Platform and/or the avail the Services and/or policies and/or claims, and/or to fulfil any other applications, request or expressions of interest by you.

b) Our Platform may also collect mobile numbers for verification to check the active SIM status on the device, uniquely identify you and prevent fraud and unauthorized access. When you grant us access to the address book on your mobile device, then we access the names and contact information from your address book to facilitate invitations and to assess your phone usage and habits. 

c) As part of your journey on the Platform, we may access your phonebook contacts which includes their contact names, phone numbers, account types, favorites (starred) and contact labels to enrich your profile.

d) We may collect transaction information related to the use of our Services, including the type of Services requested, date and time the Service was provided and payment method.  

e) Additionally, if someone uses your promotion code, we may associate your name with that person and their usage of the Platform/ Services. 

f) If you call our call center/s, we may record information provided by you to service you as per the Terms of Use and this Policy, including for quality and training purposes. 

g) When you grant us access to the SMSs on your mobile device, then we or service partners) may collect financial SMS data stored on your mobile device. We use this data to analyse your financial profile and enable provisioning of best offers by us with respect to the platform, services and/or products offered by us. We may collect non-personal data as specified in the section below.  

B. NON- PERSONAL INFORMATION / DATA

a) “Non-Personal Information” means and includes any information that does not reveal Your specific identity, such as, browser information, information collected through Cookies (as defined below), pixel tags and other technologies, demographic information etc. Our Platform gathers some information automatically when You visit the Platform or avail any Service and stores it in your log files.

b) We may collect certain non-personal information about Your computer or other electronic device through which you have accessed Platform or our Services to facilitate, evaluate and verify your use of Platform.  

c) We collect data about how you interact with our Services or Platform. 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 or in the course of interacting with our Services. 

d) “Cookies” are small files that reside on Your computer's/ electronic devices hard drive and generally contain an anonymous unique identifier and are accessible only by Platform that placed them there and not any other sites. You may refuse to accept Cookies by activating the setting on Your browser which allows You to refuse the setting of Cookies. However, if You do not provide such information, you may be unable to access certain parts of Platform. Unless You have adjusted Your browser setting so that it will refuse Cookies, our system may issue Cookies when You log on to Platform. The use of Cookies by Our partners, advertisers or service providers is not covered by this Policy. 

e) We collect non-personal 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.

f) We collect the location data from you in two ways: (i) when you add the pin code as part of your account creation process; and (ii) from your mobile device when enabled by you to do so. 

g) We collect the data about your installed applications, including the applications that you have installed on and from the date you create your account on the Platform and the manner in which you use them.

h) IT IS REITERATED THAT THIS POLICY DOES NOT APPLY TO PROCESSING OF ANY DATA IN ANONYMISED, AGGREGATED OR DE-IDENTIFIED FORM AVAILABLE WITH US OR COLLECTED BY US OR PROVIDED TO US. THE USE OF SUCH NON-PERSONAL DATA / INFORMATION (INCLUDING RETENTION, SHARING AND PROTECTION) SHALL BE AT OUR SOLE DISCRETION AND AS PER OUR REQUIREMENTS.

C. How We Use Your Personal Information

We and our affiliates may use and share the personal information or data (including any sensitive personal information) provided by you or collected from you for the following purposes:

a) provide and improve the Platform and/or the services offered by or through the Platform including but not limited to personalizing user experience and sending you information and updates about new products, your insurance policy, your premium due dates, etc. This could include displaying appropriate content based upon our / our affiliates’ judgment and discretion.

b) undertake KYC checks and verification including to establish and verify your identity.

c) undertake the on-boarding process or creation of your account on the Platform.

d) conduct research and analysis to develop new products / services, improve our services / Platform, or to detect, prevent, mitigate and investigate fraudulent or illegal activities.

e) analyse how the Platform and/or the Services are used, diagnose service or technical problems, maintain security.

f) pre-filling / auto-filling forms, details or information;

g) help You efficiently use and access the Platform or the Services or any part thereof. 

h) to look at trends and customer interests. We may combine information we get from you with information about you we get from third parties.

i) send You and/or your contacts (as permitted by you) notifications, updated and newsletters.

j) monitor aggregate metrics such as total number of viewers, visitors, traffic, and demographic patterns.

k) to enable us to comply with any legal and regulatory obligations or requisition requests by any authority under the applicable laws including to enable Us to proactively communicate with IRDAI, or law enforcement agencies or any other government or judicial body in connection with any suspicious, illegal, fraudulent or unlawful activities.

l) to enforce legal rights against you.

m) for enabling customer support to you including to help us to respond to your pre-sale and post-sale requests and support needs, including any claims and/or payout requests, efficiently and without delay.

n) for enabling communications with you including for enabling marketing and outreach activities including promotion of new products, services, and/or platforms offered on or through the Platform.

o) to help avoid repeat tests or checks or questions to and by You, and to allow You / Your co-applicants to avail the additional products, services or other new offerings.

p) to contact You / Your co-applicant or otherwise communicate with You / the co-applicants to offer new products, services, facilities, features and/or discounts, as the case may be.

q) for automated/automating decisions.

r) assess serviceability of services or features offered.

s) perform internal operations necessary to provide our Services or the Platform, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

t) to market the Platform, Services or other products / services. This includes sharing your feedback, ratings and screen names for purely promotion, marketing and other related purposes. Even if your name appears in the Do Not Call or Do Not Disturb Register, we may contact you through e-mails, telephones, messages, SMS, WhatsApp or any other available modes for marketing schemes, various financial or other products or any other aspect pertaining to any services availed by you or in which you have shown interest. You acknowledge that (i) such communication will not cause any inconvenience to you; (ii) for any claim against or by any third parties, we will not be liable. Such promotion and marketing may be done, inter alia, via hoardings, banners, pamphlets, calls, SMS/es, emails and other means as we deem fit.

u) To contact you for refund or cancellation or confirmation of a purchase or failed transaction or the claims or payout process with respect to the Services, products and/or policies availed by you or wherein you have expressed interest or intent of purchase.

v) We use information to send you transactional communications. We might send you emails or SMS/es or messages through other technology enabled messaging apps about your account, or use of the Services or the Platform or a policy purchase.

D. Sharing of Your Personal Information

a) With Our affiliates and/or our group companies: We may share the personal information or details provided by you or collected by us, with our affiliates or members of our group for the purposes specified under Section C (How We Use Your Personal Data) of this Policy. 

We reserve the right to exchange, share or provide the personal information relating to your personal, financial details and other sensitive information, with our affiliates and other group companies as required, and you will not hold us/our affiliates and/or our any other group companies and their employees or agents liable for use, processing, retention or sharing of the personal information as per this Policy including Section C (How We Use Your Personal Data) of this Policy. 

YOU UNDERSTAND AND AGREE THAT WE MAY DISCLOSE YOUR PERSONAL INFORMATION, TO ANY MEMBER OF OUR GROUP OR OUR AFFILIATES OR OUR RELATED PARTY, FOR THE PURPOSES SPECIFIED UNDER SECTION C (HOW WE USE YOUR PERSONAL DATA) OF THIS POLICY, AND YOU PROVIDE YOUR EXPRESS AND UNCONDITIONAL CONSENT FOR THE SAME.

b) With Third Party Service Provider/s and Partners: We or our affiliates may use other third-party service providers to help operate our business, the Platform, provide the Services or administer activities on our / our affiliates’ behalf, such as sending out newsletters, surveys or questionnaires or other marketing activities. We may disclose your information to third parties (including any foreign third parties) for the purposes mentioned under Section C (How We Use Your Personal Data) of this Policy, inter alia, in order to perform KYC checks, provide You with customer support facilities, to comply with Our legal obligations including prevention of money laundering or otherwise as prescribed by the IRDAI or under any applicable laws, to enforce Our Terms of Use, to facilitate marketing and advertising activities for us and/or our affiliates, to conduct analysis, to provide You services, to facilitate services for You, to send notifications, reminders or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to Platform and to avail services from third parties for data analysis and market research. Some of these functionalities may includes: Analysing customer behaviour, conducting research into customer behaviour and contacting the customers for the said purpose, and to automate our marketing and outreach efforts, Detection and flagging of fraud, Cloud services, Validating and authenticating your employment status, employment information and employment duration. 

c) With Authorities or as required by Applicable Laws: We may disclose or share your personal information if we are under a duty to comply with any legal obligation under any Applicable Law, or upon request / or an order from the government and/or a statutory, regulatory or law enforcement authority, or in order to enforce or apply our / our affiliates’ rights in the Terms of Use. This includes exchanging personal information with other companies, organizations for the purposes of fraud protection and credit risk reduction.

d) For Business Requirements: In the event the Company or its affiliates is / are merged with, or acquired by another company, or in case of re-organization or re-structuring of business or other investment activities, we or our affiliates may share your personal information, wholly or in part, with another business entity/ies.

E. Retention Policy

We collect, share and retain your personal information only for the purpose specified above, including ensuring compliance with applicable laws. Subject to regulatory or law enforcement requirements or other obligations under applicable laws which may prescribe longer periods, we will retain your personal information in identifiable form until you withdraw your consent. To withdraw your consent, you may write to the grievance officer as per the details mentioned in the “Contact Us” section.

F. How Acko Protects Your Information

We, at Acko General, have appropriate data collection, storage, and processing practices. Our security measures protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our website. All kinds of private information exchange and transactions on the Platform happen through secured communication channels, are encrypted and protected with digital signatures.

We assume no liability for any disclosure of personal information due to errors in transmission, unauthorised third-party access, or other acts of third parties, or acts or omissions beyond Our reasonable control and you agree that you will not hold us responsible for any breach of security or unauthorised disclosure. In using Platform, you accept the inherent security implications of data transmission over the internet, and the world wide web cannot always be guaranteed as completely secure. Therefore, your use of Platform will be at your own risk.

G. Third Party Websites

While using the Platform, you may find content that contains links to the other websites or portals on the internet. We do not control the content or links that appear on these sites and are not responsible for the practices of such websites. Additionally, these websites, apps or services, as well as the content and links thereon, may be changing a fee. These sites, apps, links and services may have their own terms of use and privacy policy/ies. Browsing on and interacting with any other website, app or link, including the websites, apps, links which contain a link to our website, is subject to their respective terms and conditions.

H. Changes in this Privacy Policy and Other Terms

We have taken every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy. This Policy does not apply to any information other than the personal and sensitive information and does not extend to any non-personal data provided by you or collected by us. This Policy shall be inapplicable to any unsolicited information you provide us through Platform or otherwise. This includes, but is not limited to, information posted in any public areas of Platform. All unsolicited information shall be deemed to be non-confidential, and the Company shall be free to use and/ or disclose such unsolicited information without any limitations. Acko General reserves the right to update this Policy at any time, so you are advised to review this Policy statement frequently. 

Ⅰ. Contact Us

If you have any questions, comments or grievances in relation to our privacy policy as outlined above, you may write to our Grievance Office at: [email protected]