Privacy Policy
1. Introduction
Refyne Tech Private limited (hereinafter referred to as "the Company”), through its Website and Mobile Application called "Refyne” runs an employee financial wellness platform that allows the employee users to track their salary and enables them to withdraw on credit, the earned amount of salary at any point of time at an agreed transaction fees which credit is extended by Non-Banking Financial Companies with whom the Refyne has arrangements.
The terms used in the Privacy Policy ("Policy”) have the meaning as defined in the Terms of Use. The present policy lays down how Refyne collects, uses, discloses, shares and transfers Information of User Employees including You.
By using or accessing the Refyne platform or opening an Account on the Refyne Platform, You agree to accept the present Policy and You hereby consent to Refyne collecting, processing, using, disclosing, sharing and transferring Your Information and personal data including but not limited to sensitive Personal Information. This Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder and the Digital Personal Data Protection Act, 2023.
In case You do not want to share Information as contained herein below for use by Refyne as stated, You are free to opt out or not use the Refyne platform by deleting the Account and in such a case, are not required to give consent as per the present Privacy Policy
In case in the future You intend that Your Information as collected should not be used or should be deleted, You can withdraw Your consent as provided in the present Policy, by writing to Refyne platform revoking the said consent or deleting the Account, as the case may be.
Refyne reserves with itself rights to modify, change or update this Policy at any time. Continued accessing of the Refyne platform or use of the Products and Services shall be deemed to be Your acceptance of this Policy or amendments thereof.
2. Collection of Consent
The Company collects Your consent by giving to You a notice containing the following information:
- The personal data and the purpose for which the same has been processed;
- The manner in which You may withdraw Your consent.
- The grievance redressal mechanism and how You may exercise Your rights under the
same - The manner in which You may make a complaint to the Board
This notice shall be in a plain and easy to understand language and shall be available to You in any of the languages mentioned in the Eighth Schedule of the Constitution.
You can choose to give the consent on Your own or through a Consent Manager affiliated with the Data Protection Board.
3. Processing of Information and its Purpose
Refyne collects, uses, discloses, shares and transfers Information, other content, communications, information provided by User Employees, when the Users use the Refyne platform or the Products and Services, for the purpose of providing the User Employees with their Products and Services.
Purpose of collecting the information is to enable the User Employees to access and avail the Products and Services available on the Refyne Platform.
For the purpose of these Terms, the term "Personal Information” shall mean any information You or the Employer provides to Refyne which is used to identify You and shall include, without limitation Your name, gender, date of birth, age, phone number, photograph, Your financial information such as bank account or credit card or debit card or other payment details, Your email ID and password, Your employee identification number with the Employer, official email id, Your employment history with the Employer, attendance details KYC details (PAN, Aadhar Card, Address Proof, Salary Slip, account details and bank statements, income tax returns etc.). For the purpose of this Policy, the term "Non-Personal Information” shall mean information that does not specifically identify an individual but includes information from You such as the type of internet browser You use, mobile device or computer You use, Your mobile device's unique device ID, Your, Your Internet Service Provider (ISP) and Your Internet Protocol (IP) address.
Personal and Non-Personal Information together is referred to as "Information”. Refyne may collect Information from You when You open an Account or fill the Application Form, when you use the features or the Products and Services, when You participate in surveys conducted, when You interact with the customer care team, when You carry out transactions on the Refyne platform. You specifically undertake and warrant the accuracy and truthfulness of the Information You share and agree that You shall be solely responsible for the same. You shall keep updating the information provided, periodically, in the event the information changes. You can change the information, by sending an email to the grievance redressal officer, whose details are mentioned below.
You agree to indemnify Refyne, against all losses, damages, claims, penalties, costs arising out of the inaccuracy of the information provided.
Refyne may use cookies to monitor and manage Your usage of the Refyne platform including, without limitation, for simplifying Your experience when You return to Refyne platform, like remembering Your login ID and certain Personal Information, deliver relevant content based on Your preferences, usage patterns and location, tracking etc..
Refyne may collect details about Your use of the Refyne platform and/or Products and Service, such as the features used, any activity carried out and the frequency/duration/time thereof, the actions taken etc.
Refyne may access, use and collect organizational contact data of the user from their hand-held device to empower users to share the app with their coworkers and promote financial wellness at work.
Refyne may be required to collect and combine details from and about the mobile phones, computers, tablets, and other electronic devices that You may use to access the Refyne platform. Details that may be obtained from these devices could include:
Operating system, hardware and software versions, storage space signal quality, battery level, browser type, plugins, name of mobile operator or ISP, language, time zone, IP address, connection speed and installed app data to provide users with the best credit options
Network, camera or photos, beacons and mobile phone masts, advertising details and data from cookies stored on devices to collect information regarding users' engagement on application. Such information will help us in enhancing user experience on the Application.
Location-related details including Your current location through precise device location, IP addresses, GPS location to provide improved usage and for tracking as provided in the Terms of Use.
4. Information Usage
Refyne may use Your Information to:
- Manage Your Account.
- Providing access to the Refyne platform and/or use of the Products and Services.
- Send SMS for authenticating operations via One Time Password (OTP) etc.
- Conduct survey or analysis of Your Account.
- Develop, test and improve the Refyne platform, testing and troubleshooting, rectifying
glitches, improving navigation and the facilitation of Products and Services.
5. Information – How It May Be Shared
Refyne may disclose or share Your Information which includes Your Personal Information to enable providing of Products and Services:
- Sharing with NBFC's or credit information companies Information shared by You may be disclosed and shared with NBFC and/or credit information companies, as the case may be, in order to enable You to avail the Salary Advance Facility.
- Disclosure as required by law or to authorities. Your Information may be shared with authorities such as government/statutory authorities or under court orders; to establish or exercise legal rights; to defend against legal claims; or as otherwise required by law.
- Disclosure to third parties including payment gateways Refyne may be required to provide, disclose or share Information, that is collected from You to third-party service providers to provide and ensure availability of Products and Services, payment gateways.
- Sharing of Information with prospective suitors or acquirers Information may be required to be disclosed acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity or business of Refyne.
- Develop, test and improve the Refyne platform, testing and troubleshooting, rectifying
glitches, improving navigation and the facilitation of Products and Services.
Refyne shall ensure the following, with respect to the Personal Data shared with third-parties:
- In the event, You withdraw Your consent, Refyne shall ensure that all the third-parties with whom the data has been shared, delete the same, subject to any regulatory requirements.
- Refyne shall enter into a valid contract, with the third-parties, with whom Personal Data may be shared.
Refyne shall not share Your Personal Data outside the jurisdiction of India, unless such sharing has been explicitly permitted under the Applicable law.
6. Protection Of Information
Refyne, on best effort basis shall attempt to take appropriate security and technical measures to protect the security of Your Information including Personal Information and to ensure that Your choices for its intended use are honoured.
Refyne takes adequate precautions, on best effort basis, to secure and protect Your data from loss, misuse, unauthorized access or disclosure, alteration or destruction, by using industry standards of physical, technical and administrative security measures although You agree that the same cannot be foolproof since no security system is impassable and accordingly Refyne cannot and does not commit or guarantee that the Information may be absolutely free from invasion or breach.
Refyne shall not be liable or responsible for any breach of security or disclosure of Your Information by or for any actions or inactions of the NBFC or any other third party that receives Your Information.
You are solely responsible for maintaining the confidentiality of Your username and password and Refyne would, in no circumstances be liable or responsible for any breach in this regard by You.
In the event of any breach by Refyne or any third-party to whom Your Personal Data has been shared, Refyne shall duly intimate You and the Data Protection Board, in accordance with the Applicable law.
7. Your Rights As A Data Subject
- Access Rights: You have the right to request access to the following information about Your Personal Data collected:
- In the event, You withdraw Your consent, Refyne shall ensure that all the third-parties with whom the data has been shared, delete the same, subject to any regulatory requirements.
- the identities of all other Data Fiduciaries and Data Processors with whom the personal data has been shared by along with a description of the personal data so shared; and
- any other information related to the personal data and its processing, as may be permitted under Applicable law.
- Right to correction and Erasure of Personal Data: You have the right to correction, completion, updating and erasure of Your personal data for the processing of which You have previously given consent.
- Right to grievance redressal: You shall have the right to have readily available means of grievance redressal through a grievance redressal mechanism set up by Refyne.
- Right to Nominate: You shall have the right to nominate any other individual, who shall, in the event of Your death or incapacity shall, exercise Your rights as outlined under the applicable law.
8. Your Obligations Aa A Data Subject
You represent and warrant to comply with the following obligations:
- comply with the provisions of all applicable laws as updated from time to time
- to ensure not to impersonate another person while providing Your personal data for a specified purpose;
- to ensure not to suppress any material information while providing Your personal data for any document, unique identifier, proof of identity or proof of address issued by the State or any of its instrumentalities;
- to ensure not to register a false or frivolous grievance or complaint with a Data Fiduciary or the Board; and
- to furnish only such information as is verifiably authentic, while exercising the right to correction or erasure under the applicable law.
- to update the Personal Data provided, as and when the same changes.
9. Mechanism For Grievance Redressal
In accordance with the Information Technology Act, 2000 and Rules made thereunder, and the Digital Personal Data Protection Act the contact details for raising grievances, if any are provided below:
Address: Prestige Pegasus, Sarjapur - Marathahalli Rd, Ambalipura, Haralur, Karnataka 560103
Contact Number: 080-64899999 You may file Your complaint or raise any queries/requests by sending an email to the aforementioned email address. Our Grievance redressal officer shall revert to Your complaint/query/request within the legally stipulated timelines.
Last reviewed on: 22nd March 2024
