PRIVACY POLICY

This Privacy Policy (“Policy”) explains how Acko Technology and Service Private Limited, and the Insurance Providers (identified in the Terms of Use) collect, store, use, transfer and otherwise process your data (save and except non-personal data / information), for providing you the Platform and/or the Services (defined in the Terms of Use, available on the Platform) through the Platform.

IN ORDER TO FACILITATE AND PROVIDE YOU (AND CO-APPLICANTS, MEMBERS, NOMINEES, APPOINTEES, IF ANY) WITH THE SERVICES THROUGH THE PLATFORM, THE COMPANY, ACKO GENERAL INSURANCE LIMITED AND ACKO LIFE INSURANCE LIMITED NEED TO COLLECT VARIOUS DATA AND INFORMATION, BOTH PERSONAL AND SENSITIVE, FROM YOU WITH YOUR PRIOR AND EXPLICIT CONSENT.

ACCEPTANCE OF THE PRIVACY POLICY:

YOU WARRANT AND CONFIRM THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY, AND YOU PROVIDE YOUR UNEQUIVOCAL CONSENT TO ALLOW US AND OUR INSURANCE PROVIDERS TO COLLECT, RETAIN, SHARE, PROCESS AND STORE YOUR PERSONAL AND SENSITIVE PERSONAL INFORMATION AS PER THIS POLICY. IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT PROCEED FURTHER TO USE / ACCESS THIS PLATFORM OR AVAIL ANY SERVICES / PRODUCTS OF THE INSURANCE PROVIDER. 

BY SETTING UP YOUR ACKO ACCOUNT OR VOLUNTARILY PROVIDING US / OUR INSURANCE PROVIDER OR ALLOWING US / OUR INSURANCE PROVIDER ACCESS TO YOUR PERSONAL INFORMATION, YOU ARE CONSENTING TO COLLECTION, PROCESSING, STORAGE, USAGE AND SHARING AS PER THIS POLICY. 

If you do not provide personal information or withdraw the consent for any of your personal information at any point in time, we and/or the Insurance Providers shall have the option to not 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 by us or our Insurance Provider as the case may be. 

PLEASE FURTHER NOTE THAT WITHDRAWAL OF CONSENT BY YOU OR DELETION OF YOUR ACKO ACCOUNT WILL NOT DIMINISH AND/OR AFFECT OUR / OUR INSURANCE PROVIDER/S RIGHTS AND/OR OBLIGATIONS UNDER THE APPLICABLE LAWS. ACCORDINGLY, YOU UNDERSTAND AND AGREE THAT WE AND OUR INSURANCE PROVIDERS 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 ONLY APPLIES TO YOUR DATA INCLUDING ANY PERSONAL AND SENSITIVE PERSONAL DATA/INFORMATION. ANY NON-PERSONAL DATA / INFORMATION PROVIDED BY YOU TO US OR OUR INSURANCE PROVIDERS OR OUR SERVICE PROVIDERS; OR COLLECTED BY US OR OUR INSURANCE PROVIDERS OR OUR SERVICE PROVIDERS, IS OUT OF THE SCOPE OF THIS POLICY. 

NON-PERSONAL INFORMATION SHALL BE USED, SHARED, STORED AND/OR PROCESSED BY US AND/OR OUR INSURANCE PROVIDER AS PER OUR / OUR INSURANCE PROVIDERS’ 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. 

We and the Insurance Providers will use the personal information including any sensitive personal data / information provided by You only in accordance with the purposes in this Policy or as per the requirements of the applicable laws. 

Except as provided herein or as clearly disclosed to You at the time of seeking or collection of sensitive personal data, we do not solicit any sensitive personal information about you. However, if you share such sensitive or personal information with us or the Insurance Providers voluntarily, we will not be liable for any actions, claims, costs, expenses or other liabilities that may arise because of any unauthorized use or misuse of such sensitive personal information. Any personal information including your sensitive personal information provided by you on the Platform or to us or to the Insurance Provider/s, will be deemed as an authorisation given by you to us and the Insurance Providers to use, store, process and share such personal information for the purpose as stated out on the Platform, the applicable laws, the policy wording 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 Insurance Providers:

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 or any product of the Insurance Provider. 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 or Insurance Provider (including by e-mail, feedback and/or surveys).

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

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 or the Insurance Providers or our affiliates to perform KYC, health or other checks and extend the services to you, as further detailed in this Policy. 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.

e) You also consent to the use, disclosure and sharing of the personal information about You, including but not limited to information about your health, physical attributes, medical history and lifestyle, etc. by Acko Tech, the Insurance Providers, Our affiliates and/or Our group companies. This will help You avoid repeat queries/tests, and also help You avail the additional products, services or other new offerings by Acko Tech or Insurance Providers, Our affiliates and/or Our group companies 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 and/or Insurance Provider 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. 

b) We and /or Insurance Provider 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 Insurance Providers, 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 and/or the Insurance Providers: 

a) We and the Insurance Providers collect 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 (i) create Your Acko Account; (ii) provide our Service and Platform; (iii) enable the Insurance Providers to provide you with products and/or services; (iv) perform verification and KYC checks on you; (and it is also used to auto populate relevant fields when you apply for any product or service of the Insurance Provider. 

b) We and the Insurance Provider may also collect mobile numbers for verification to check the active SIM status on your 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 and the Insurance Providers 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 and Insurance Provider shall collect transaction information related to the use of our Services, the Platform and/or the products and services of the Insurance Provider, 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 or the Insurance Provider may associate your name with that person and their usage of the Platform/ Services. 

f) If you call our call centers, we or the Insurance Providers 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 and our Insurance Provider collect financial SMS data stored on your mobile or other device. We and the Insurance Provider use this data to analyse your financial profile and enable provisioning of best offers by us and/or Insurance Providers with respect to the Platform, Services and/or products offered by us or the Insurance Providers. 

h) We may collect non-personal data as specified in the section below.  

ⅰ. “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.

ⅱ. We and the Insurance Providers may collect certain non-personal information about Your computer or other electronic device through which you have accessed Platform or our Services or the products / services of the Insurance Provider to facilitate, evaluate and verify your use of Platform or Your Acko Account or your interactions / communications with the Insurance Provider.  

ⅲ. We and the Insurance Providers collect non-personal data about the devices used to access our / their 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.

ⅳ. We collect non-personal data about how you interact with our Services, Platform and/or with the Insurance Provider. This includes data such as access dates and times, 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 and/or the services/products of the Insurance Providers. 

ⅴ. “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. 

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

ⅶ. 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.

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

We and/or the Insurance Providers may use, process and share your personal information including any sensitive personal information / data for:

ⅰ. Enabling the Platform and the Services offered by us and/or the Insurance Provider, including:

a) provide and improve the Platform and/or the Services.

b) to enable provisioning of products / services by the Insurance Providers 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 / Insurance Providers’ judgment and discretion.

c) to provide you with single Your Acko Account to enable you to access / view the details with respect to your policies, premiums, etc. from both the Insurance Providers conveniently, and connect directly with the respective Insurance Providers from Your Acko Account in case of any updates, information and/or queries with respect to the products and/or services of the Insurance Provider and/or your policies with the Insurance Provider. 

d) undertake KYC checks and verification including to establish and verify your identity on behalf of the Insurance Provider. This may also include retaining, sharing and using the personal data provided by you (to us or the Insurance Provider) for the KYC checks, to provide services now or in the future, including to auto-populate any applications you may make now or in the future, with the Insurance Provider/s or otherwise.

e) perform internal operations necessary to provide our Services or the Platform including to enable us to provide you all the relevant details with respect to policies in an easy viewing format on Your Acko Account, or to enable the Insurance Provider to provide the products and/or services to you including updates on your policy through Your Acko Account or otherwise, including to troubleshoot software bugs, operational problems or to conduct testing.

f) providing details with respect to your policies on Your Acko Account.

g) the Insurance Providers shall share your policy level data with Acko Tech to enable You to view and access the details with respect to your policies through Your Acko Account, and you hereby provide your explicit consent for the same.

h) to help avoid repeat tests or checks or questions to and by You, and to allow You to avail the additional products, services or other new offerings by Us, the Insurance Providers, our affiliates and/or our group companies.

i) to enable Us, Our affiliates and group companies to contact You or otherwise communicate with You to offer new products, services, facilities, features and/or discounts as the case may be.

ⅱ. Enabling customer support including:  for enabling customer support to you including to help us / Insurance Providers respond to your pre-sale and post-sale requests and support needs, efficiently and without delay, including through Your Acko Account or otherwise.

ⅲ. Research, development, improvements and innovation including:

a) to conduct research and analysis to develop new products / services, improve our / Insurance Providers services, or to develop features and functionality to detect, prevent, mitigate and investigate fraudulent or illegal activities.

b) analyse how the Platform and/or the Services are used, diagnose service or technical problems, maintain security for us and the Insurance Provider.

c) help you efficiently use and access the Platform or the Services or any part thereof; or any products / services offered by the Insurance Provider through Your Acko Account. 

d) to assess serviceability of services, products or features offered by us or the Insurance Provider or any other affiliate / group company of Acko Tech, and to send you communications with respect to the same.

e) to contact you for refund or cancellation or confirmation of a purchase or failed transaction on the Platform or with the Insurance Provider including to display the status of your payments, applications, inquiries and/or policies on Your Acko Account. 

f) to look at trends and customer interests with respect to our Services, and/or the products / services of the Insurance Providers, whether offered now or in the future. We and/or the Insurance Providers may combine the information we / Insurance Provider receives from you, with the information we / Insurance Provider gets from other third parties including any of the service providers.

ⅳ. Enabling communications including: for enabling communications through Your Acko Account or otherwise, including for enabling marketing and outreach activities including promotion of new products, services, and/or platforms offered by us or the Insurance Providers or our group companies / other affiliates, and for automated/automating decisions. We and the Insurance Providers will use and share your personal information to send you transactional communications. We or the Insurance Provider may send you emails or SMS/es or other push notifications about Your Acko Account or your expression of interest or purchases.

ⅴ. Marketing and outreach including: to inform you about the new products offered by us, the Insurance Providers or any other group company. 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 the Insurance Providers. Accordingly, you may contact us; or we or the Insurance Provider may contact you. By contacting us / the Insurance Provider in anyway and/or by providing us / the Insurance Provider your phone number and/or contact details and/or other details or showing interest in any product / service of the Company or the Insurance Provider or any other affiliate / group company, you thereby give us, the Insurance Provider and/or other affiliates the unequivocal right and consent to use the said personal data as per this Policy.

ⅵ. Ensure compliance under applicable laws including:

a) to enable us or the Insurance Provider to comply with any legal and regulatory obligations or requisition requests by any authority under the applicable laws including to enable us or the Insurance Provider 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.

a) to enforce our / the Insurance Providers legal or other rights against you including to comply with our / Insurance Providers obligations to you.

ⅰ. With Our other affiliates and/or our group companies: We may also share the personal information or details provided by you or collected by us with our other affiliates or members of our group companies for the purposes specified under Section 3 (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 3 (How We Use Your Personal Data) of this Policy. This right is in addition to the rights of the Insurance Provider to access, use, store and share your personal data as per Section 3 (How We Use Your Personal Data).

YOU UNDERSTAND AND AGREE THAT WE AND THE INSURANCE PROVIDER MAY DISCLOSE YOUR PERSONAL INFORMATION, TO ANY MEMBER OF OUR GROUP OR OUR AFFILIATES OR A RELATED PARTY, FOR THE PURPOSES SPECIFIED UNDER SECTION 3 (HOW WE USE YOUR PERSONAL DATA) TO THIS POLICY, AND YOU PROVIDE YOUR EXPRESS AND UNCONDITIONAL CONSENT FOR THE SAME.

ⅱ. With Third Party Service Provider/s: We or the Insurance Providers or our other affiliates may use third-party service providers to help us operate our business, perform KYC checks, manage the Platform, provide the Services or administer activities on our, Insurance Providers / our other affiliates’ behalf, such as sending out newsletters, surveys or questionnaires or other marketing activities with respect to us, the Insurance Provider or our other affiliates’ products / services, including any new offerings. We may disclose your personal information to third parties (including any foreign third parties to the extent permitted by the applicable laws) for the purposes mentioned under Section 3 (How We Use Your Personal Data) to this Policy, inter alia, in order to perform KYC checks, provide You with customer support facilities, to comply with our / Insurance Providers legal obligations including prevention of money laundering or otherwise as prescribed by the IRDAI or under any applicable laws, to enforce the Terms of Use, to facilitate marketing and advertising activities for us, Insurance Provider and/or our other 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 or the products / services of the Insurance Provider 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. 

ⅲ. With Authorities or the Government: 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 the 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.

ⅳ. 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, the Insurance Provider or our other affiliates may share your personal information, wholly or in part, with another business entity/ies.

We and the Insurance Providers collect, use, share and retain your personal information only for the purpose specified in the preceding sections 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.

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

We or the Insurance Provider 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 / Insurance Providers reasonable control and you agree that you will not hold us / Insurance Provider responsible for any breach of security or unauthorised disclosure. In using Platform and/or availing the services or products of the Insurance Provider, 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 including to avail any products / services offered by the Insurance Provider will be at your own risk.

While using the Platform, you may find content that contains links to the other websites or portals on the internet. 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.

We and the Insurance Providers have taken every effort to ensure that this Policy adheres to 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 including sensitive information and does not extend to any non-personal data provided by you or collected by us / our Insurance Provider / other affiliates / by our service providers. 

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. We and the Insurance Providers reserves the right to update this Policy at any time, so you are advised to review this Policy statement frequently. Your access to or continued use of the Platform after the changes have been posted on this page shall confirm your equivocal acceptance of the revised privacy policy.

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 below:

Acko Life Insurance Limited

Acko General Insurance Limited