THIS PRIVACY POLICY (“Policy”) describes our policies and procedures for collection, use, storage, disclosure and protection of any personal information, including, but not limited to, any sensitive information provided by you or collected by us while using the Platform and/or availing the Services. BY VOLUNTARILY PROVIDING US OR ALLOWING US TO ACCESS THE PERSONAL INFORMATION, 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. 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 DIMISH 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. 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 provided by You only in accordance with the purposes described in the applicable laws and/or this Policy. Except as provided herein or as clearly disclosed to You at the time of collection 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, 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 and our affiliates 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: You may provide the personal information to us or our affiliates:

a) 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. This may include contact information such as name, email address, mailing address, phone number, KYC documents like Voter ID, PAN, Driving License, etc.

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

c) You may be required to provide further information to Us or our affiliates for the purposes of issuance of policies and processing of claims. Such additional information may include (without limitation) your health and lifestyle related data, bank statements, loan statement, salary and income statements as prompted on the relevant page. You may also be required to provide this information to us via physical documents, e-mail or other digital and offline methods.

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, etc.) and may lawfully receive information about you from such sources. Such personal data may be shared internally and combined with data 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 and non-personal data, 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 and on-boarding process to provide our Service and it is also used to auto populate relevant fields during the interface of our Platform.

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 access your phonebook contacts which includes their contact names, phone numbers, account types, favorites (starred) and contact labels to enrich your profile.

d) We, 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 centers, we or our affiliates 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 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 and/or our affiliates with respect to the platform, services and/or products offered by us or our affiliates. 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 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 ANNONYMISED, AGGREGATED OR DEIDENTIFIED 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 REQUIREMENTS.

C. How We Use Your Personal Information

We and/or our affiliates may use and share the personal information or data provided by or collected from You for the following purposes:

a) provide and improve the Platform and/or the services offered by Us or our affiliates 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) help You efficiently use and access the Platform or the Services or any part thereof. g) to look at trends and customer interests. We may combine information we get from you with information about you we get from third parties.

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

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

j) 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.

k) to enforce our legal rights against you.

l) for enabling customer support to you including to helps us / our affiliates respond to your pre-sale and post-sale requests and support needs efficiently and without delay.

m) for enabling communications with you including for enabling marketing and outreach activities including promotion of new products, services, and/or platforms offered by us or our affiliates or group companies.

n) for automated/automating decisions.

o) assess serviceability of services or features to you.

p) 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.

q) to market the Platform, Services or the products / services of our affiliates. This includes sharing your feedback, ratings and screen names for purely promotion and marketing 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, by us or our affiliates or our group companies or any third party duly engaged by us.

r) To contact you for refund or cancellation or confirmation of a purchase or failed transaction on the Platform.

s) We use information to send you transactional communications. We might send you emails or SMS/es about your account or a policy purchase.

t) By accessing or using Platform or the Service, you will be able to see the service offered / facilitated by Us and/or our affiliates. You may have interest or intention of availing services or a general query with respect to the services available on Platform and/or through Platform and/or by our affiliates. Accordingly, you may contact us, or we may contact you. By contacting us in anyway and/or by providing us your phone number and/or contact details and/or other details or showing interest in any product / service of the Company or its affiliates, you thereby give us and/or affiliates the unequivocal right to use the said personal data as per this Policy.

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 agents liable for use, processing, retention or sharing of the personal information for use as per 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: We or our affiliates may use third-party service providers to help us 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 with respect to us or our affiliates products / services, including new offerings / services. 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 include: Analysing customer behavior, conducting research into customer behavior 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: We may disclose or share your personal information if we are under a duty to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply Our Terms of Use or assign such personal information during corporate divestitures, mergers, or to protect the rights, property, or safety of the Company, the Users, or others. This includes exchanging personal information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

d) For Business Requirements: In the event the Company is merged with or acquired by another company or in case of re-organization or re-structuring of business, 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 right to the grievance officer as per the details mentioned in the “Contact Us” section.

F. How Acko Protects Your Information

We, at Acko, 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 SSL secured communication channels and 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. Our intentions are always to link only to websites that are agreeable to our high standards of right to user privacy, however we do not control the content or links that appear on these sites and are not responsible for the practices employed by such websites. Additionally, these websites or services, as well as the content and links thereon, may be constantly changing. These sites and services may have their own privacy policies. Browsing on and interacting with any other website, including the websites which contain a link to our website, is subject to that website’s own 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 Life 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]