SCOPE
The scope of this Privacy Policy ("Policy) include the collecting,
recording, organizing, storing, modifying, using, disclosing, or deleting
Customer, Employee and Company related data. For details of such
definitions reference is drawn to the Information Technology Act, 2000
read with all statutory amendments carried forth therewith ("Act")
including all other relevant Laws, Rules, Bye Laws or Standing orders
passed by competent authorities within India applicable to each
Company and as amended from time to time. This includes personal
information that is collected in India from individuals located outside of
India and then transferred outside of India. Any treatment of all such
data including its collection, storage, usage be fully protected in
accordance with this policy and Privacy Rules.
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Applicability
This policy applies to BOB Financial Solutions Limited
(hereinafter referred to as "BFSL" or "the Company") and all its
Employees, Officers, Directors, Advisors, Consultants other
Personnel, and all third party service providers who act on
behalf of the Company and collect, process and use personal
data, profile data, financial and other within India and outside.
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Effective Date
This Policy has been issued on 13th December 2018 and is effective 13th December 2018 onwards
DEFINITIONS
- Provider of Information: The individual who provides the
information (i.e., the data subject). The Term "Person" is defined
to mean and include natural persons as under stood under the
applicable Indian laws.
- Personal information: Any information that relates to a natural
person, which, either directly or indirectly, in combination with
other information available or likely to be available with a body
corporate, is capable of identifying such person.
- Sensitive Personal Data or Information of a person: means such
Personal Information which consists of information relating to ─
- Password
- Financial information such as Bank account or credit card or debit card or other payment instrument details
- Physical, physiological and mental health condition
- Sexual orientation
- Medical records and history
- Biometric information
- Any detail relating to the above clauses as provided to body corporate for providing service
- Any of the information received under above clauses by body corporate for processing, stored or processed under
lawful contract or otherwise.
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Public Information: Any information that is freely available or
accessible in public domain or furnished under the Right to
Information Act, 2005 or any other law for the time being in
force shall not be regarded as sensitive personal data or
information for the purposes of this Policy.
- Company or Body Corporate means the body corporates as
defined in Section 43A of the IT Act 2000 and for the purposes of
this Policy means and refers to BFSL.
- Password means a secret word or phrase or code or passphrase
or secret key, or encryption or decryption keys that one uses to
gain admittance or access to information.
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Aggregated information: This information does not identify the
individual; it helps us to analyze patterns among groups of
people. We may share Aggregated Information or De-identified
Information in several ways, for example:
- for the same reasons as we might share Personal Information;
- with Business Partners to help develop and market products or services and present targeted content, including Targeted
Advertising;
- with Business Partners to conduct analysis and research about customers, website and app users;
- with Third-Party Ad-Servers to place ads (including ads of our Business Partners) on various websites and apps,
and to analyze the effectiveness of those ads
POLICY
- Data will be processed fairly and lawfully
- Data will be collected for specified and legitimate purposes and
not processed further in ways incompatible with those purposes
which have been duly explained, communicated to and
consented by each person concerned
- Data will be relevant to and not excessive for the purposes for
which they are collected and used. For example, data may be
rendered anonymous when feasible and appropriate, depending
on the nature of the data and the risks associated with the
intended uses
- Data will be kept only as long as it is necessary for the purposes
for which it was collected and processed and in accordance with
data storage requirements under various applicable local laws
- Data will be processed in having full regard to each person’s
lawful rights (as described in these Standards or as provided by
appropriate law)
- All appropriate technical, physical, and organizational measures
will be taken to prevent unauthorized access, unlawful
processing, and unauthorized or accidental loss, destruction, or
damage to data
SECURITY PRACTICE
BFSL will ensure Reasonable Security Practices and Procedures including but not limited to the following:
- Comprehensive documented information security programme
and information security policies that contain managerial,
technical, operational and physical security control measures
that are commensurate with the information assets being
protected with the nature of business are available
- In the event of an information security breach, BFSL or a
competent and duly authorized person having knowledge of
and in possession of information relating to such security breach
shall be prepared to demonstrate, as and when called upon to
do so by the regulatory agency created under the applicable law,
that the Company has taken all bonafide measures and have
implemented security control measures in accordance with the
BFSL documented information security programme and
information security policies together with standards and codes
of best practices in letter and spirit.
- Such policies, standard or the codes of best practices have been
certified or audited on a regular basis by entities by an
independent auditor
CONSENT
The Company while collecting information from the Provider of
Information, data, sensitive personal data and other financial
information will try to ensure that, in addition to obtain consent:
- The Provider of Information understands the purpose for the
collection; the intended recipients of the information
- The Provider of Information will also have an option not to
provide or withdraw their consent. The company can decline
goods/services for which info was sought
- Prior permission from the person is required for disclosure to
any third party (except as may be required to be disclosed by
law)
- Providers will have access to review, correct or amend
information provided
- Data may be transferred in line with the consent (i.e., provider
knew purpose/intended recipients when giving information) in
India or to any country so long as same level of data protection
is provided
- The consent obtained by the Company be of a nature and extent
so as to fulfill the requirements of a lawful contract between the
Provider of Information and the Company
- If access or rectification is denied, the reason for the denial will
be communicated and a written record will be made of the
request and reason for denial. In this case the person affected
may make use of the dispute resolution processes described in
law
- If the person demonstrates that the purpose for which the data is
being processed is no longer legal or appropriate, the data will
be deleted, unless the law requires otherwise
OBLIGATIONS
This Policy includes an obligation to provide actual notice to
individuals when personal information is collected. BFSL will establish
and make this privacy policy available to all persons. BFSL will also
grant the persons the right to access and correct personal information.
In addition, BFSL is committed to secure information and establish a
dispute resolution process that applies to the collection and use of all
personal information
Collection and Use of Sensitive Data:
- In addition to the general obligations, there are obligations
specific to the collection, use, and disclosure of sensitive personal
data. Sensitive personal data is broadly defined to include
password; financial information (bank account, credit/debit card,
or other payment instrument details); physical, physiological, and
mental health conditions; sexual orientation; medical records and
history; and biometric information. Any information that is freely available or accessible in the public domain or furnished under
the Right to Information Act, 2005, is excepted from the definition.
- Notwithstanding anything in this Policy any sensitive personal
data on Information shall be disclosed to any third party by an
order under the law for the time being in force.
Disputes:
- Any discrepancies or grievances will be addressed in a timely
manner by the Company. A Grievance Officer and such other
personnel designated to assist that grievance officer shall be
designated, and his or her name and contact details are at all-time
be published on the company’s website. The Grievance Officer is
singularly responsible for and accordingly redresses the
grievances expeditiously (but within one month from the date of
receipt of the grievance).
Cookies:
- BFSL’s digital platforms use various third party services to promote
its products and services. These third party services use cookies which
are downloaded to your device when you visit a website in order to provide
a personalized browsing experience. Cookies are used for lots of tasks like
remembering your preferences & settings, provide personalized browsing experience
and analyze site operations. These cookies collect information about how users use
a website, for instance, how often visited pages. All information collected by
third party cookies is aggregated and anonymous. By using our website user/s agree
that these types of cookies can be placed on his/her device. User/s is free to
disable/delete these cookies by changing his/her device / browser settings.
BFSL is not responsible for cookies placed in the device of user/s by any other
website and information collected thereto.
