Last update 20/03/2023
Zerobalance Technologies Private Limited, a private limited company having its registered office at F/402 Satva Apartments, Shantivan, Paldi, Ahmedabad, Gujarat - 380007 (hereinafter referred to as “We”, “Us”, “Our”, “Company”, "Zerobalance", "GoldPe", “GoldPe” or "GoldPe") which owns and operates the website www.goldpe.app and/or the mobile application ‘GoldPe’ available at Android/ iOS platforms (collectively referred to as the “Online Platforms”) for the purpose of providing digital gold buying and selling platform to any natural or legal person (hereinafter referred to as “You”, “Your”, “User”, “Customer”) is committed to protecting your privacy and the information that you share while using the Online Platforms.
2. Scope of this Policy
3. Policy Review, Updates & Applicability
4. Information Collected
We collect information about you when you use our app, register for an account, make a transaction, contact us for support, etc.
We may collect such information about you which enables us to operate our business and deliver and improve our Services including but not limited to the information that personally identifies you including name, contact details, identification information, organisation, department, any financial information including inter alia credit card, debit card details, bank account and know your customer (KYC) documents, biometrics, and information relating to the use of Online Platforms including device information, technical information, transactional information (collectively referred to as the “Personal Information”). Thus, we may collect and process the following information about you:
Information You Give Us: You may be required to give us Personal Information about yourself while visiting the Online Platforms and/or availing any of our Services or corresponding with us by phone, e-mail, chat or when we troubleshoot problems reported by you. The information you give us may include without limitation: Personal details, including but not limited to date of birth, age, marital status, birthplace, nationality, mother tongue, photographs, signature specimen and Government-issued identifiers including but not limited to Aadhar, PAN.
Contact information, including but not limited to name, postal address, telephone number and email address;
Financial information, including but not limited to bank account details, credit/debit card details, credit score/ credit information report, e-KYC, billing information, tax information and payroll information (as applicable); and
Other information, that GoldPe is required to collect as per specific mandate from partner bank/non bank/PPI issuer or as a requirement under applicable law, regulation, rule or statute in India.
We may also occasionally require you to participate in optional surveys. Your Personal Information may be collected through such surveys. We may also require additional information about you for performing ongoing due diligence (necessitated under the applicable law) based on your risk assessment, transaction value, etc.You must ensure that all your data and/or information shared with us is accurate, correct and complete, at all times. You understand that you must promptly inform us of any changes to your data and/or information which may impact your use of our Services. We shall not be liable or responsible for any loss or damage that may occur to you or other third parties on account of provision of incorrect data and/or information provided by a user.
Information We Collect About You: With regard to each of your visits to any of the Online Platforms, we may automatically collect and analyse the following demographic and other information:
Device Information: Information obtained with consent from your mobile phone or other access device. It includes device ID, device type, geo location information, connection information, mobile network information, transactional and promotional SMS, communication information including contacts and call logs.
Technical information: Information including the Internet Protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other similar information.
Access Information: Information including the full Uniform Resource Locators (URL) clickstream to, through and from the Online Platforms including date and time; information about transactions and trades executed or attempted to be executed by you; material or information that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information including scrolling, clicks, and mouse-overs, and methods used to browse away from the page and any phone number used to call our customer service number.
Transactional Information: For enabling you to make payments while accessing Services through our Online Platforms, we may store your financial information such as your bank account or details mentioned on your credit cards or debit cards, or other payment instrument details etc. that are required for a successful transaction. We also store transaction details such as amount spent, counterpart details, beneficiary information, account balance, transaction ID, date and time of transaction. Further, we may also store information relating to your income, lifestyle levels and usage pattern.
Correspondence Information: For quality and training purposes or for its own protection, GoldPe may monitor or record its telephone conversations with you or anyone acting on your behalf. By communicating with GoldPe, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.
In addition to above, for the mobile version of the App, we may collect any other authorization or information that enables GoldPe to provide a smooth mobile experience, including but not limited to, SMS access for auto OTP verification, camera/gallery/contacts access and any other permissions required to enable certain functionalities within the mobile application.
Information We Receive from Other Sources: We may receive information about you if you use any of the other websites/apps we operate or the other services we provide. Such data may be shared internally and combined with data collected through use of the Online Platforms. We also work closely with select third parties including, for instance, subcontractors such as advertising networks, analytics providers, search information providers and may receive information about you from such sources. We collect non-personally identifiable information to track the total number of visitors to the Online Platforms in aggregate form and identify the type of internet web browser and operating system used by the visitor. This information allows us continuously to improve the Online Platforms and Services.
Account Deletion Policy: At GoldPe, we prioritize your privacy and are committed to providing you with control over your personal information. If you wish to delete your account and associated data, you have the right to request its deletion.
5. Express Consent
You also specifically agree and consent to us and our group or affiliate companies collecting, storing, processing, transferring and sharing information (including Personal Information) related to you with third parties such as banks, non banking financial instituitions, prepaid instrument issuers, financial institutions, credit information companies, entities registered under applicable laws solely for the purpose of reviewing your profile and processing your transaction requests for the Services or for such other products/services offered by us or our group, affiliate or associates.
In addition to the above, we identify and use your IP address to help diagnose problems with our server, resolve such problems and administer the Online Platforms. Your IP address is also used to help identify you and to gather broad demographic information. We may occasionally ask you to complete optional online surveys. These surveys may ask you for your contact information and demographic information including zip code, age, or income level. We use this information to tailor your experience at the Online Platforms, providing you with content that we think you might be interested in and to display content according to your preferences. We use your Personal Information to send you promotional emails, however, we will provide you the ability to opt-out of receiving such emails from us. If you opt out, the Company may still send you non-promotional emails, such as emails about the Services and your Account on the Online Platforms. Unless and until, you explicitly give your consent to us, to do so, we will not share your Personal Information with another user of the Online Platforms and vice versa.
6. User access of Personal Information
As a registered GoldPe User, you can view and modify some of your Personal Information and your privacy preferences by accessing the “Account” section of the Online Platforms.
7. Use of Your Information
Our primary purpose in collecting Personal Information is to provide you with a secure, smooth, efficient, and customized experience. We may use your Personal Information for the following:
1. to provide and improve the Services on the Online Platforms that you request;
2. to resolve disputes and troubleshoot problems;
3. to help promote a safe service on the Online Platforms and protect the security and integrity of the Online Platforms, the Services and the users;
4. collect money from you in relation to the Services,
5. inform you about online and offline offers, products, services, and updates;
6. customize your experience on the Online Platforms or share marketing material with you;
7. to detect, prevent and protect us from any errors, fraud and other criminal or prohibited activity on the Online Platforms;
8. enforce and inform about our terms and conditions;
9. to process and fulfill your request for Services or respond to your comments, and queries on the Online Platforms;
10. to contact you;
11. to allow our business partners and/or associates to present customized messages to you;
12. to communicate important notices or changes in the Services, use of the Online Platforms and the terms/policies which govern the relationship between you and the Company and with our affiliates for providing Services to you;
13. and for any other purpose after obtaining your consent at the time of collection.Further, we may use the data and Information collected/ stored as mentioned above for providing or improving our Services, improving user experience, risk checks, strengthening our security checks, for analysis and for offering you new features in the existing Services you are availing or offering altogether new product/ service which may be relevant for you. We collect and use some of your information in an aggregated form to compile statistical and demographic profiles for our business and marketing activities and to customize our Services to you.
8. Disclosure of information
We may also disclose your Personal Information to third party vendors, consultants, and other service providers who work for the Company, who are bound by contractual obligations to keep such personal information confidential and use it only for the purposes for which we disclose it to them. This disclosure may be required for us, for instance, to provide you access to our Services and process payments including validation of your bank accounts, to facilitate and assist our marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services.
We do not disclose your Personal Information to third parties for their marketing and advertising purposes without your explicit consent.
GoldPe may disclose your information, to the extent necessary: to comply with laws and to respond to lawful requests and legal process,to protect the rights and property of the Company, our users, and others, including to enforce the terms, and in an emergency to protect the personal safety and assets of the Company, the users, or any person.In such an event GoldPe is in no manner responsible for informing you or seeking your approval or consent. We and our group entities or affiliates (to the extent Personal Information is collected by them) may, in compliance with applicable laws, share/transfer/assign all of your Personal Information and other information with any other business entities, in the event of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of our business.
9. Security Practices
We have implemented appropriate security measures to protect your information from unauthorized access, use, or disclosure. We regularly review and update our security practices to ensure that your information remains safe and secure.
We store and process your personal information on our computers where our facilities are located. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We have fully ensured that the reasonable security practices adapted by GoldPe are fully in compliance with the applicable laws and at par with the industry standards.
10. Data Retention
GoldPe may, at its sole discretion, retain any information and/or data provided by you for as long as your Account is active, for resolution of disputes, for the purpose of investigations or ongoing prosecutions or in case of any suspicious/illegal transactions, for enforcement of any agreements, and/or as necessitated under applicable laws. The retention period may be extended in accordance with the applicable law.
Post termination of your relationship, GoldPe may be contractually or legally obligated to retain certain information and accordingly such information shall be retained as prescribed under the applicable law or part of GoldPe’s contractual obligation. We may keep your contact information along with your application details (if any) for fraud prevention purposes and for the exercise/ defense of a legal claim or for providing evidence in legal proceeding(s).
Post termination of your relationship, GoldPe may use your anonymized data aggregated or in combination with anonymized data of other users. We may use this aggregated anonymized data for data analysis, profiling and research purposes, for example to gain insights about our users and their profiles.
11. Amendments & Updates to the Policy
We use data collection devices such as "cookies"/similar, etc on certain pages of the app to help analyze our app page flow, measure promotional effectiveness, and promote trust and safety.
A cookie is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. We use cookie and tracking technology depending on the features offered. No Personal Information will be collected via cookies and other tracking technology; however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties.
If you choose to use our referral service to tell a friend about the Online Platform or GoldPe, we may ask you for your friend's name, phone number and email address. We will automatically send your friend a message inviting him or her to visit the Platform. We store this information for the sole purpose of sending this message and tracking the success of our referral program.
14. Grievance Officer
If you have grievance or complaint, questions, comments, concerns or feedback in relation to the processing of information or regarding this Privacy and Security Policy or any other privacy or security concern please feel free to reach out to the grievance officer, the contact details of this officer have been provided below: