Your access to the Coupl Platform and its usage is subject to your compliance with all the terms and conditions set forth herein, read along with all documents, including but not limited to; applications forms and undertakings, signed by you during account opening, and any terms, consents, policies included on the App or Website, including our Terms of Service (the “Terms of Service”). Capitalized words not defined herein will have the definitions attributed to them in the Terms of Service.
This Policy tells you how we use, disclose, and protect information collected while using the Services. This Policy covers only information that is collected through the Services provided by us and excludes other websites that may be linked to or from the Services or the practices of companies that we do not control, employ or manage.
Your continued use of the Coupl Platform is deemed to be construed as your acceptance of this Policy and by accepting the Policy, you are expressly consenting to our collection, use and disclosure of your information as described in this Policy and to all other terms herein.
If you have any questions regarding this Policy or any other issue related to what is covered in it, please contact us as at the email address provided in the “Contact Details” section.
WHAT INFORMATION DO WE COLLECT?
We collect information from you when you use the Services or the Coupl Platform, including without limitation, when you create an account, update your profile, make a transaction, or contact customer support.
Coupl may collect any information that is not in the public domain concerning the business and/or finances of each of the Parties for the purpose of determining their identity and verifying their background, whether or not reduced to writing and whether or not patentable or protected by copyright or the law of trade secrets including, without prejudice to the generality of the foregoing, reports, interpretations, forecasts, documents and information as required from individuals or other entities under the Reserve Bank of India’s (“RBI”) Master Directions on KYC, corporate business plans, financial projections, financial details and accounts, products, services, planned products, planned services, marketing and advertising plans, marketing and advertising requirements, budgets, fee levels, customer/client lists, commissions, commission charges, pricing policies technical know – how concepts and all information about research and development. Coupl may update the KYC records of its customers on a periodic basis to ensure that the documents, data or information collected is kept up-to-date and relevant by undertaking reviews of the existing records once in every two years for high risk customers, once in every eight years for medium risk customers and once in every ten years for low risk customers from the date of opening of the account / last KYC update.
Before you can use the Coupl Platform, you must create a user account with us. When you create an account, we collect your contact and other information. This includes, without limitation, the following information:
Your account credentials will include your username, password, and other information for authentication and account access.
When you sign up for the Services, certain fees and charges may be applicable. These charges are nominal, transparent and disclosed by Coupl upfront from time to time, so that you know what you are paying or being charged for.
For any other information you choose to voluntarily provide to us that we do not request, you are solely responsible for the provision of such information. Coupl will not be responsible and/or liable for handling any such information that we have not expressly requested.
Since our Services revolve around the financial services and banking industry, we also collect certain information regarding your personal finances, goals and preferences in order to offer Services that suit your requirements.
We automatically collect information when you use the Services, through tracking technologies like cookies, web beacons, tags and scripts, software development kits (or SDKs) and any other technologies that are being deployed in the industry from time to time. The categories of information we automatically collect include:
We may also collect information from publicly-available sources, including data in the public domain.
We are constantly improving the Services and we often introduce new features that require the collection of new information, or use what information we already have differently. If our collection or use of information materially changes, we will notify you as detailed in the“Policy Changes”section below.
Coupl may use third-party advertising companies to serve advertisements on our behalf. These companies may employ cookies and action tags (also known as single-pixel gif or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous.
Coupl may be responsible for facilitating RBI, NPCI, PCI DSS, ISO and other agencies nominated by RBI/ NPCI, to access the data, information, systems of technology service providers related to the Services and carry out audits as and when required by RBI and NPCI.
HOW DO WE USE YOUR INFORMATION?
The above activities can involve outside companies, agents, or contractors (“Service Providers”) with whom we share your information for these purposes.
We may share your information with:
For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
Our Service Providers may provide us with a variety of administrative, statistical, and technical services. We will only provide Service Providers with the minimum amount of information they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and advise all of our Service Providers to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights (as applicable).
PASSWORD AND SECURITY
FOR HOW LONG DO WE KEEP YOUR INFORMATION?
We will hold your information on our systems for as long as required to provide you with the Services you have requested; or to perform the purpose for which that information was collected; or to maintain a record in our system after you have ceased using our Services; or to comply with any applicable laws. Whenever you sign up to receive email marketing from us, we will retain your email address on file should you ever ‘opt-out’ of receiving emails from us. We will retain your email address in this way in order to ensure that we continue to honour and respect that opt-out request. In some circumstances, you can ask us to delete your data. See the “Your Rights and Choices” section below for further information.
Except as otherwise expressly included in this Policy, this Policy addresses only the use and disclosure of information we collect from you. If you disclose your information to others, whether they are users of the Services or other apps throughout the Internet, different rules may apply. The Services may, from time to time, contain links to and from the Services of our partner banks, financial services providers, networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal information to these external websites.
We reserve the right to limit access to Services to those over 18 years of age, however, if you are below 18 years of age, please ensure that your parent or guardian has reviewed this Policy. Your use of our Services binds your parent or guardian as if they are the users of the Services.
YOUR RIGHTS AND CHOICES
You may request a record of your Personal Information being processed by us, subject to the verification of your identity and other information required by us.
You may review, correct or rectify the inaccurate Personal Information that is stored with us.
Where we send you e-mail marketing communications you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication or through your account or by following the unsubscribe instructions provided in the email you receive). If you opt-in to receive push notifications we will use the information you give us to provide you with those notifications and improve future notifications. Alternatively, if for any reason you cannot use the methods described above, or if you would prefer to contact us directly – you can unsubscribe by writing to us and telling us which communications you would like us to stop sending you.
When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. If necessary, we may ask you to provide copies of relevant ID documents to help us to verify your identity. It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
HOW TO CONTACT US
In accordance with Information Technology Act 2000 and rules made thereunder, the contact details of the Grievance Officer are provided below for your reference:
Coupl Software India Private Limited
WeWork Prestige Atlanta, 80 Feet Main Road, Koramangala 1A Block, Industrial Layout, Bangalore, Karnataka - 560034, India
Coupl Technologies, Inc.
355, Bryant Street, San Francisco, California, USA
Coupl Software India Private Limited is a wholly-owned subsidiary of Coupl Technologies, Inc.