Privacy Policy | Cushy Pay

We at Cushy pay, i.e., Omniware Payments Private Limited and its subsidiaries ("the company/ Cushy pay/we/us/Cushy pay") are committed to defending the privacy and security of your personal data. Your privacy is vital to us, and maintaining your trust is our top priority.

This privacy policy document describes how we collect, use, manage, and disclose the information of our customers. By using our website/app and other affiliated services, you provide consent to our privacy policy terms ("privacy policy") and our terms of use as well. We encourage you to peruse this privacy policy concerning the collection, usage, and disclosure of your data from time to time to know the changes & updates made.

This privacy policy defines our privacy practices for all websites, products, and services linked to it. Nevertheless, this policy does not apply to those affiliates and partners that have their own privacy policy. In those situations, we recommend that you read the privacy policy on the applicable site. Any capitalized terms not defined hereunder shall hold the exact definition as provided in terms of use.

1. Data We Collect

The subsequent information is collected by or on behalf of Cushy pay.

1.1 Information you give

After you start using the app amenities, we ask you to provide certain data as a part of the registration procedure. Throughout your interaction with the app, we will collect this data through various means and in multiple places through the app services, as well as contact us forms, account registration forms, or when you otherwise interact with Cushy pay including customer support.

During the time of registration, we ask for the following personal information. Name (first name, last name); ; e-mail id; mobile number date of birth; pan card.

According to the services you consume from time to time, we may explicitly seek additional information, including address, payment or banking information, Cushy pay score, Cushy pay/debit card details, and other government identification documents or numbers. You may opt to provide such information if you desire to use the services offered by the app.

Also, we will maintain a record of the data you provide to us while using the customer support.

Now and then, at some point in your use of the app services, Cushy pay may require access to specific additional information such as SMS & contact details. Before accessing any such further information, explicit consent shall be sought from you. Please note that we only read promotional or transactional SMS and do not access, open, or read any private SMS even after you have provided consent.

A few features may be restricted, inaccessible, or unusable if you choose not to provide certain data. For instance, you would not be able to avail of any rewards or e-commerce transactions involving delivery if you choose not to share an address for delivery.

1.2 Information created while using our app services

Cushy pay gathers information relating to your usage of our website/app through the usage of various technologies. This comprises transaction details related to your usage of our services, as well as the type of services requested by you, the amount, payment method, and other related financial and transactional information. Additionally, depending on the rewards that are claimed by you or e-commerce orders filed by you, we may collect the order details, delivery information, etc. Furthermore, when you visit our website/app, we may log specific details such as IP address, mobile operating system, browser type, manufacturer and model of your mobile device, preferred language, geolocation, access time, and time expended. We will also collect data about the pages you view inside our sites and other actions you may take while visiting our app/ website.

We also maintain a few records of users who contact us for support to respond to such queries and other linked activities. Nevertheless, we do not provide this data to any third party without your authorization or utilize the same for any purpose not set out here.

1.3 Information collected from third parties

We may, with your permission, request certain third parties to provide data about you to personalize further your experience on our app/ website and provide specific services that cannot be accessed by all users of the website/app.

Cushy pay is currently open only to Cushy pay cardholders who have a Cushy pay score more than or equal to 750, independently determined by third-party service providers that you expressly authorize to process such data and distribute the same. For example, Experian, a Cushy pay information company registered under the Cushy pay information companies (regulation) act, 2005, is among our partners. To check if you meet the above worthiness, you will be requested to provide us with explicit consent to procure the Cushy pay information, from our partners, at the time of registration.

Suppose you choose to link and connect your e-mail account with Cushy pay. In that case, we may access the said account for purposes including collecting your Cushy pay card bills details such as total due amount, minimum due amount and due date, and other such financial and transactional information to be able to do the following:

• Manage all your Cushy pay card information in one place, including reminding you of the payment due before the due date;

• Curate offers and rewards customized for you;

• Offer insight into your expenditure pattern(s) to make sure you are aware of your expenses and can make wiser choices basis the same;

• Curate specific investment/ financial/other products for you based on your financial transactions, investments, and past financial behaviour.

Cushy pay's access to the e-mail account(s) is authorized through the e-mail provider's access mechanism. If you permit the Cushy pay website/app to track your Cushy pay card accounts, the Cushy pay website/app will securely store account details for each of your Cushy pay card accounts, including your sign-in user name and authorization tokens for tracked accounts.

Please note that your consensus to any of the above is purely voluntary. You can opt to enable us to access one or more of your e-mail accounts by explicitly consenting to every single account separately. You can de-link the access to your e-mail any time you wish.

We only read e-mails from financial service providers, including banks and Cushy pay card issuers, and do not open, read, or access personal e-mails. We confirm that we do not access any other personal information. For the sake of clarity, Cushy pay employs automated processes for accessing and analysing data you provided, where we may need to use our algorithm to access a password-protected document utilizing information provided by you.

We may receive additional data about you, such as information to help detect fraud and safety issues, from third-party service providers and/or partners and merge it with data we have about you. We may collect data about you and your actions through partnerships or concerning your experiences and exchanges from our partner ad networks.

2. How we use the data we collect

Cushy pay may store, use, and process the data provided by you to (1)enhance the app services, (2)establish and maintain a trusted and safe environment on Cushy pay (such as observing our legal obligations and compliance with our policies), and (3) provide, personalize, gauge and improve our services and products.

The data collected through different channels allows us to collect statistics about our website/app usage and effectiveness, personalize your experience while you are on our website/app, customize our interactions with you, and enhance the extent of the app services. The following sections define in more detail how we use your personal data.

2.1 Providing, Comprehending & Improving app services

Any data you provide will be used for generating and updating your account and managing your transaction(s) or for any other reasons you have granted us access to such information, based on your interaction with the Cushy pay app.

In order to complete a financial transaction, we may share financial information (such as Cushy pay card details or other payment mode particulars) provided by you with authorized third parties, for instance- financial teams/institutions, our business partners, or postal/government authorities involved in the fulfilment of the said transactions, if applicable. This does not include any data collected from e-mails. In association with a financial transaction, we might contact you as part of our client satisfaction surveys or market research.

We may use the data collected to perform internal operations essential to services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, and monitoring and analyse usage and activity trends. Cushy pay processes this personal data for these purposes, provided our legitimate interest in refining the app services.

Apart from the transactional information made available to us, we may seek your consent and request access to your e-mail account. If permitted, Cushy pay will automatically access the contents of e-mails on an ongoing basis to manage the complete Cushy pay card lifecycle, including due date reminders, Cushy pay card statements, spend patterns and related rewards, curating offers and customizing rewards, providing insights into your financial choices including both investment and spending, curating certain financial/investment/other products for you based on your financial transactions, investments, and past financial behaviour, etc. To increase the scope of our app services, we may, at times, seek additional data and financial documents such as data related to investments in mutual funds, equity, and other documents. Such collection of additional data & documents shall be subject to explicit & purpose specific consent sought from all users.

The Cushy pay website/app will securely store account details for each of your Cushy pay card accounts, as well as your sign-in user name and authorization tokens for tracked accounts. This data will be used to enable the Cushy pay website/app to automatically access your applicable Cushy pay card statements to analyse, extract, and store information securely from such accounts for use in the Cushy pay app/website.

2.2 Safety, Security, and Resolution of problems

We may utilize your personal data, created as part of payment facilities availed by you, to make sure that your access and use of payment services comply with our legal requirements (such as regulations against money laundering). We might share such information with our advisors, third-party service partners, and providers for a continuous experience.

We may use the data to create and maintain a secure environment and utilize the same to identify and prevent fraud, spam, security incidents, abuse, and other harmful activities.

We use the data we collect (including recordings of client support calls) to assist you when you connect with our customer support services to inspect & resolve your queries, scrutinizes and enhance our customer support responses. Specific online transactions may involve us interacting with you. They may also include online chats. Please be mindful that it is our general practice to screen and, in some cases, record such exchanges for staff training or quality assurance reasons or to retain evidence of a specific interaction or transaction.

We intend to defend your personal information and to maintain its accuracy, as confirmed by you. We implement realistic administrative, physical, and technical safeguards to help us defend your personal data from unauthorized use, access, and disclosure. For example, we encrypt all sensitive personal data such as Cushy pay card information when transmitting such data over the internet. Also, we require that our commercial partners and vendors protect such data from unauthorized use, access, and disclosure.

Cushy pay blends security at multiple steps within our products with state-of-the-art technology to ensure our systems uphold strong security measures. The general data and privacy security design allow us to defend our systems, ranging from low hanging issues to complicated attacks.

We are dedicated to protecting your data as if it were our own. Suppose you are a security enthusiast or a researcher and you have found a possible security vulnerability on Cushy pay products. In that case, we encourage you to convey the issue to us responsibly. You could put forward a bug report to us at support@cushypay.in with detailed steps essential to reproduce the susceptibility. We shall put our best efforts into investigating and fixing the legitimate issues in a realistic time frame, meanwhile requesting you not to disclose them publicly.

2.3 Disclosure and Sharing of data with third-parties

As required by law, at times, we may be required to disclose your personal data, including transactional, personal, and financial information, to relevant regulatory and governmental authorities and our advisors such as law and audit firms while answering requests from the regulatory authorities. In some cases, when we trust that such disclosure is essential to protect our rights, or others' rights, or to comply with a legal proceeding, court order, or legal process served on our app/ website, we would share such information under a lawful request from law enforcement agencies.

Subject to explicit and prior authorization from you, we might use data created by your use of our app services, not counting data collected from other sources such as e-mails, etc., for the purposes of marketing. This consent is purely optional, and you may at any time choose not to receive marketing materials from us by adhering to the unsubscribe instructions included in each e-mail that you may receive, by signifying so when we call you, or by contacting us directly. Furthermore, if you want to remove your contact data from all our lists and newsletters, do click on the unsubscribe button on the e-mails or send an e-mail request to support@cushypay.in.

Subject to unequivocal and prior consent from you, we may disclose specific information created by your usage of our app services, not including data collected from other sources such as e-mails, etc., to other associate entities and partners that are not acting as our suppliers or commercial partners. For the sake of lucidness, we do not sell or lease such information.

Some of our campaigns/programs/related events may be co-branded, that is, sponsored by both the third parties and us. If you sign up for such campaigns/programs/associated events, please note that your information may also be collected and shared with those third-parties. We urge you to familiarize yourself with their privacy policies to understand how they will handle data about you.

We may exhibit targeted, or non-targeted third-party online advertisements on the Cushy pay app/ website. We may also promote our activities and organizational goals on other apps/ websites. We may collaborate with another app/ website operators as well as network advertisers for this. We implore you to read and understand such concerned third-party privacy policies to comprehend their practices related to advertising, including what type of data they may collect about your internet usage. No personally identifiable data is shared with any third-party online advertiser or website, or app as part of any such activity. Cushy pay does not provide any information relating to your usage of such network advertisers or website operators.

All through your use of the app services, you may come across links to third-party websites/apps not affiliated with Cushy pay. Cushy pay is not responsible for the privacy practices or the content of those other websites or any acts/ omissions by such third-parties in the course of your transaction. Throughout your utilization of the app services, you may come across links to third-party websites/ apps that are not affiliated with Cushy pay. We are not liable for the privacy practices or the content of those other websites or any acts/ oversights by such third-parties during your transaction with them.

3. Account/card removal

We provide all our users an opportunity to request the deletion of a specific account through the support section on the Cushy pay app. Subsequent to such a request, we delete all such information related to the particular account, counting but not limited to profile data, transaction details, reward details, statement details, referrals details, card data, Google OAuth sessions, etc., which we are not obligated to retain.

We may be unable to remove your account in certain circumstances, such as if any outstanding dispute or unresolved claims are pending on your card/account. Nevertheless, upon resolution of the issue preventing deletion, the information is immediately deleted and can't be recovered henceforth. Note that we may retain certain data if necessary for our own legitimate business interests, such as fraud stoppage and enhancing users' safety and security, or to fulfil our legal obligations and compliance.

You also have the choice to request an account or card deactivation/archival instead. This will temporarily block your access to Cushy pay app until you send a re-activation request on support@cushypay.in and successfully re-activate your account.

4. Cookies

Certain parts of the app help analyse the app services, user interaction with the app, measure promotional effectiveness, and promote trust and safety. We use data collection policies such as "cookies," etc. For clarity, "cookies" are small files placed on your device's hard drive/storage that support us in providing the app services. Please be informed that we offer specific features via the app that are only accessible through the use of a "cookie."

Cushy pay also uses cookies to allow you to enter a specific password less frequently during a session. Cookies also help us acquire information that assists us in curating the services more focused on your interests. You are always welcome to reject our cookies if your device permits, though, in that case, you may not be able to use particular features on the app, and you may be obliged to provide a password more frequently during a session.

5. Changes to the privacy policy

Cushy pay reserves the right to modify this policy from time to time. Any changes shall be operative immediately upon the post of the revised privacy policy. We urge you to periodically review this page for the latest info on our privacy practices.

6. Privacy queries and access

If you have concerns, questions, or suggestions concerning our privacy policy, we can be reached through the contact data on our "contact us" page or at support@cushypay.in. In some cases, you may have the ability to view or edit your personal information online. If your information is not accessible online, and you wish to obtain a copy of the detailed data you provided to us, or if you become conscious of the fact that the data is incorrect, and you would like us to correct it, please get in touch with us immediately.

Prior to providing you with any information or correct any inaccuracies, nevertheless, we may ask you to verify your identity and offer other details to ascertain your identity and help us respond to your appeal. We will communicate with you within 30 days of your request.

7. Compliances

We are an iso 27001:2013 certified company and have implemented required information systems management system policies and procedures in order to maintain industry-standard best practices and appropriate controls.

We have completed "data localization" requirements as per Reserve Bank of India (RBI) guidelines. This means all our customer data securely reside inside on cloud-based out of India.

Cushy pay's use of information received from Google APIs will adhere to Google API services user data policy, including the limited use requirements.

8. Grievance redressal officer

For any complaints regarding our privacy policy or data usage practices, please reach out to support@cushypay.in.