Privacy Policy

Coupl Software India Private Limited, is a company incorporated under the Companies Act 2013 (hereinafter, the“Company”, “Coupl”, “we” “us”, “its” and “our”). Coupl provides various financial services (the “Services”) through its mobile application Coupl (“App”) and website www.coupl.money (“Website”) or such other apps or websites that the Company may develop from time to time, in collaboration with its partner establishments (collectively, the “Coupl Platform”). In this Privacy Policy (“Policy”), the terms “user”, “you” and “your” refer to you, the user of our Services.

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.

INTRODUCTION

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.

This Policy supplements the Website’s Disclaimer, if any, Terms of Service and Cookie Policy, and is not intended to override or replace them, but to complement them. This policy will also be reflected in the website of the Company when available and also in the Privacy Practice Statement that may be shared with business associates where required.

If you have any questions regarding this Policy or any other issue related to what is covered in it, please contact us at the email address provided in the “Contact Details” section.

WHAT INFORMATION DO WE COLLECT?

  1. Information you provide:

    2. 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.

  2. Account Creation:

    3. 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:

      • Name
      • Phone number
      • E-mail ID
      • Date of Birth
      • Relationship Status
      • Photograph Video Verification
      • Address
      • PAN Card
      • Aadhaar Card
      • Any other information that we may require to provide a better experience on the Coupl Platform, some of which may be optional.

    Your account credentials will include your username, password, and other information for authentication and account access.

  3. Billing:

    4. 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.

  4. Voluntarily-provided information:

    5. 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.

  5. Financial Information:

    6. 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.

  6. Information collected automatically:

    7. 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:

    1. a) Transaction Information:
      • We collect information about your use of the Services when you sign-up our services, including without limitation, the financial information. Each transaction made on the Coupl Platform is recorded by our systems and attributed to your account.
    2. b) Activities:
      • We may collect your usage information based on your activities, like statistics on your preferences, practices, achievements and milestones, to offer a more seamless and better experience on the Coupl Platform.
    3. c) Other usage data:
      • Amongst other things, we may also collect computer sign-on data, features you use, the pages you view, the time of day you use the Services, traffic to and from the Services, the Services you obtain or consider and other information about your use of the Services.
      • We may collect information from marketing, data analytics and social media databases to supplement the data we collect about you. This data sometimes includes your mailing address, your gender, your age, your household income, and other demographic data.
  7. Social media platforms and other services:

    8. We may use technologies operated or controlled by other companies in our Services. Our Services include hyperlinks that connect you to websites, platforms, and other services not operated or controlled by us. From time to time and to enhance our user experience, we may allow you to link your Coupl account with third-party accounts. If you link any third-party account to your Coupl account, you authorize us to collect, store, and use the information they share with us. If we offer any such options to link third-party accounts, you can unlink your Coupl account from the third-party account at any time. We also receive information from social networks when you engage with our content, reference our Services on social media, or grant us permission to access information from the social networks. Please note that when you interact with other parties, including when you leave our Services, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services, and whether they store information in India or elsewhere. We encourage you to familiarize yourself with their privacy policies and terms of use.

  8. Publicly-Available Sources:

    9. We may also collect information from publicly-available sources, including data in the public domain.

  9. Improving the Services

    10. 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.

COOKIES

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.

ENFORCEMENT

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?

We understand the importance of your Personal and Non-Personal Information and ensure that it is used for the intended purpose only. We access, store and use the combined information we collect from you in accordance with any applicable laws to provide our Services, to conduct research and development for expanding the Services, subject to the limitations set out in this Privacy Policy and for other purposes that may be required in the ordinary course of our business. We may combine your information with information we collect from other sources to improve the website and for other business and commercial purposes. Our business purposes are set out below.

  1. We may use the information we collect about you to, without limitation:
    • fulfil the purposes disclosed whenever you provided your information to us;
    • provide and deliver the customer support you request and collect payment (where applicable) for the Services requested;
    • set up and verify your account and user profile based on your preferences;
    • provide you with features catered to the Services;
    • carrying out research, planning and statistical analysis;
    • communicating with you, including providing you with updates on changes to products, services and banking facilities (whether made available by us or through our business partners) including any additions, expansions, suspensions and replacements of or to such products, services and banking facilities and their terms and conditions;
    • managing our infrastructure and business operations and complying with internal policies and procedures;
    • addressing or investigating any complaints, claims or disputes;
    • conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive or under contractual arrangement with any of our banking or financial services partners;
    • financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
    • enter into a contract with you or to take steps pursuant to your request prior to entering into a contract;
    • use it in other ways as required or permitted by law or with your consent;
    • track, analyse and understand your trends so as to enable us to understand lacunae (such as slow response time on the Website or App) and improve your interactive experience of using our Services, our design, features and functionalities;
    • improve and develop our products and services;
    • compare information for accuracy, and verify that our internal processes work as intended and comply with legal, regulatory and contractual requirements;
    • detect and prevent fraud, cyberattacks or unauthorized robot activities;
    • assess customer satisfaction with our customer support team, comply with legal requirements, enforce our terms and policies, respond to claims that a listing or other content violates the rights of others, or protect the rights, property, or safety of any person; and
    • in any other manner that is required to comply with applicable laws or to ensure that our Services do not face any security risks in any manner.

The above activities can involve outside companies, agents, or contractors (“Service Providers”) with whom we share your information for these purposes.

SHARING INFORMATION

    We may share your information with:

    1. associated corporate entities to help detect and prevent potentially illegal acts and provide joint services to you or other users;
    2. service providers, consultants or similar contractors to support or enhance the Services or our business operations, or to carry out transactions initiated by you, like payment processing, fulfilling your orders, maintaining technology and related infrastructure, offering you customer service, measuring the performance of our recommendations, presenting surveys, distributing emails, list processing and analytics, managing and analyzing research (see “Service Providers” below);
    3. Coupl may use and share user information with reliable and reputed third-party payment gateways with whom we are associated in order to ensure a swift and comfortable payment mechanism for you.
    4. other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and solicited consent when using a specific service);
    5. law enforcement or other governmental officials, in response to a verified request relating to a criminal investigation or alleged illegal activity;
    6. persons we believe in our sole discretion necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity; and
    7. any other business entities, should we plan to work with, merge with, or be acquired by such business entities;
    8. Notwithstanding anything in this Privacy Policy, we may share information that does not identify you (including information that has been aggregated, anonymised or de-identified) except as prohibited by applicable law.

    For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

SERVICE PROVIDERS:

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

  1. Your account’s pin or other security code ( “Pin”) deserves careful thought and protection. Use unique numbers and do not disclose your Pin to anyone. If you do share your Pin or your information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your Pin, you may lose substantial control over your information and may be subject to legally binding actions taken on your behalf, including without limitation, financial actions. Coupl will have no liability of any form arising out of your Pin getting compromised for any reason.
  2. We deploy industry standard security practices to protect all our users and their information. However, despite our best efforts, your information may still be vulnerable to sophisticated hacking, phishing or other security risks faced as a result of the use of any service on the internet.

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.

APPLICABILITY

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.

CHILDREN

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

  1. Access to you information:

    2. 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.

  2. Review, Correct and Rectify your information:

    3. You may review, correct or rectify the inaccurate Personal Information that is stored with us.

  3. Withdrawing your consent
    1. You may withdraw a consent to processing that you have given us and prevent further processing of your Personal Information subject to the terms of this Privacy Policy.
    2. You may also withhold your consent prior to the collection and processing of your combined information.
    3. Withdrawal of such consent may result in a permanent closure of your account on the Coupl Platform.
  4. Your Right to stop receiving communications

      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.

  5. Exercising your rights

    6. 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).

POLICY CHANGES

We may amend this Policy at any time by posting the amended Policy on the Coupl Platform, which will automatically take effect after it is initially posted except as otherwise specified. Please revisit the App and Website periodically for the latest information on our privacy practices. Once posted, those changes are effective immediately, unless stated otherwise. Continued access or use of the Coupl Platform or Services constitutes your acceptance of the changes and the amended Privacy Policy. However, if you do not agree with the changes, please do not continue to use the Coupl Platforms or Services or submit information to us and notify us about your disagreement over an email and upon confirmation from the Company, your access to the Coupl Platform may be revoked.

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

Email : support@coupl.money

Coupl Technologies, Inc.

355, Bryant Street, San Francisco, California, USA

Coupl Software India Private Limited is a wholly-owned subsidiary of Coupl Technologies, Inc.