Privacy Policy

Introduction

Personal and non-personal data

Personal Data we collect from you

1. Personal data you give us. This is information about you that you give us by showing interest in subscribing to our PPI Wallet Service through our Sales Partner or directly downloading the app from the Google Play Store or Apple App Store using your phone or our website https://portal.ctrlpay.biz.
   Once you subscribe to our PPI Wallet service(s) as an
   • Individual Indian Citizen or add your Indian family members, the information you share to us include: Your name, e-mail address, mobile number, your KYC documents (PAN and AADHAR), CKYC Registry Number as an individual or similar personal data of your family members and other relevant personal data as part of the wallet user onboarding guidelines defined by the applicable regulator.
   • Foreign National, the information you share to us include: Your name, e-mail address, mobile number, your KYC documents (Passport and VISA), as an individual or similar personal data of your family members and other relevant personal data as part of the wallet user onboarding guidelines defined by the applicable regulator.
   • Business User, the information you share to us include: Your company name and its formation type - Proprietor/ Partner / LLP / Private / Limited, KYC documents as per the wallet user onboarding guidelines defined by the applicable regulator, mobile number and email id of the company nominated admin user as well as individual company employee enrolled.
   for availing the wallet services, to prevent any fraud and anti-money laundering and provide support to the availed payment services. If you give us information on behalf of someone else (your colleagues, friends, family members, spouse, children, relatives, etc.), you confirm that you have given them the information set out in this notice and that they have given permission to you and subsequently to us to use their information as set out in this notice.
   Apart from that, while you are using our PPI Wallet you share with us: - Your Name, Personal Bank Account number, IFSC Code, Banking Name and Last 4 digit Credit / Debit Card Number to add the money in the wallet, your UPI /VPA ID for carrying out the wallet transactions, your Geolocation to ensure that the transaction is carried out from India only and mobile device details (hardware OS, SIM and Network Info, etc. ) to bind your device to the wallet for security purposes and as per the regulator guidelines.
2. Personal data we collect about you. With regard to each of your visits to our site we will automatically collect the following information: Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, any phone number used to call our customer service number and your interaction with the customer support and grievance team.
3. Personal Data we receive from other sources: We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, social media agencies, analytics providers, search engines, relevant government agencies, credit reference agencies) and may receive information about you from them to validate certain personal data as shared to us as recommended under the applicable payment industry laws and regulations.

Legal Basis for the use of the personal data

1. Where we are legally binded to provide the wallet services once you are about to subscribe or have already subscribed with us;
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (for example, undertaking analysis and research for the purposes of improving our website user experience); and
3. Where we need to comply with a legal or regulatory obligation (for example, equal opportunities monitoring and those originating from the payment industry regulator/s).

We use your personal data in the following ways:

Information you give to us.

1. To carry out our obligations arising from any wallet service subscription agreement entered into between you and us and to provide you with the information, payment products and services that you request from us;
2. To provide you with information about other goods and services we offer;
3. To provide you, or permit selected third parties to provide you, with information about payment goods or services, usage rewards we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS or over the app) with information about payment goods and services already offered to you or for any other goods and services offered by us or our partners or provide you with goods and services as a reward for your continued usage of wallet services. If you are a new wallet user, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please write an email to us about the same to privacy@mswipe.com
4. To notify you about changes to our service;
5. To ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you.

1. To administer our site and for internal operations, including troubleshooting, customer support, data analysis and testing, research, statistical and survey purposes;
2. To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
3. To allow you to participate in interactive features of our service, when you choose to do so and to improve the quality of interaction over voice by analyzing previous interactions;
4. As part of our efforts to keep our website safe and secure;
5. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
6. To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Information we receive from other sources.

Disclosure of your personal data

1. Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries across the globe,
2. Selected Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
3. Selected Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We may disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, merchants serving or offering particular services at a specific location). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
4. Selected Analytics and search engine providers that assist us in the improvement and optimization of our site;
5. Selected Social media;
6. Regulators, relevant government agencies and institutions under the applicable law
7. Agencies and institutions where this are necessary for defending our interests in the context of judicial proceedings, or to establish, exercise or defend our legal rights.

1. In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
2. If our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
3. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Mswipe, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

Your rights

1. Right to object: You can object to our processing of your personal information. Please contact us as noted below, providing details of your objection.
2. Access to your personal information: You can request access to a copy of your personal information that we hold, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making.
3. Right to withdraw consent: If you have given us your consent to use your personal information to send you marketing emails, you can withdraw your consent at any time by clicking the "unsubscribe" link in any marketing email which you receive or by contacting us at privacy@mswipe.com.
4. Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
5. Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
6. Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
7. Nomination: You can nominate any other individual, in manner as may be prescribed by the relevant data protection authority who shall, in the event of your death or incapacity, exercise the rights in accordance with the provisions of the applicable data protection laws
8. Make a complaint: You can make a complaint about how we have used your personal information to us by contacting us as noted below, or to the Data Protection Board.

Third party websites

Information about our use of cookies

We use the following cookies:

1. Essential: These cookies are necessary for the website to function. They are usually set in response to actions made by you such as requesting our services, setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but this means some parts of the website will not work.
2. Functional: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers. If you do not allow these cookies then some or all of these services may not function properly.
3. Marketing: These cookies are set through our site by our advertising suppliers. They may be used by our suppliers to build a profile of your interests and show you relevant adverts on other websites. If you do not allow these cookies, you will experience less targeted advertising.
4. Performance: These cookies allow us to count visits to our website so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. If you do not allow these cookies, we will not know when you have visited our website.

Data retention

Changes to our privacy policy

Contact