Privacy policy

Thanks for your interest in our website at www.fliptreetechnologies.com ("Website"). By entering this Website, the visitor consents to the terms of this privacy policy ("Policy"). So please read the Policy carefully before continuing to use this site. IF YOU DO NOT AGREE WITH ANY OF THESE TERMS IN THE PRIVACY POLICY, PLEASE DO NOT USE THIS WEBSITE. If you have any questions about the Policy, please contact privacy@fliptreetechnologies.com .

By submitting his/her Information to FlipTree, the visitor will be treated as having given his/her permission to process the same in a manner provided in this policy.

WHO WE ARE

This Website is maintained and operated by FlipTree Technologies (India) Private Limited ("FlipTree", "us", "our" or "we"). In accordance with industry custom, this Website occasionally uses terminology that may be interpreted to suggest that our firm is actually a single entity. However, there is no such single entity and all of the entities that comprise our firm have their own separate legal existence

INTRODUCTION

At FlipTree, we respect the privacy of individuals/visitors and are committed to taking reasonable precautions to protect information consisting of Personal information and 'Sensitive Personal Data or Information' (SPDI) ("Information") of visitors of this Website and comply with all legal, regulatory and/or contractual obligations related to privacy. FlipTree has adopted the "Privacy by Default" principles in its approach to data privacy i.e. privacy of data and information is upheld first by default.

This policy covers the processing, storage and access to Information as required under lawful and/or contractual activities with FlipTree or otherwise required in the normal course of business. It describes FlipTree's policies and procedures on the collection, usage and disclosure of Information provided/received by natural persons and meets the requirements established under:

• The Information Technology Act, 2000 – Section 43 A;
• The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.

1. SCOPE

This policy applies to all visitors of this Website.

2. INFORMATION COVERED BY THIS POLICY

This policy applies to Information collected and processed by FlipTree consisting of the following:

2.1 Personal information is information related to a visitor or a combination of pieces of information that could reasonably allow him to be identified. Personal information may consist of full name, personal contact numbers, residential address, email address, gender or date of birth. While information such as date of birth in isolation may not be enough to uniquely identify the visitor, a combination of full name and date of birth may be sufficient to do so.

2.2 Sensitive personal data or information ("SPDI") is such personal information that is collected, received, stored, transmitted or processed by FlipTree, consisting of:

• Financial information such as bank account or credit card or debit card or other payment instrument details;
• Biometric information;
• Any detail relating to the above personal information categories as provided to FlipTree for providing service; and
• Any of the information received under above personal information categories by FlipTree for processing, stored or processed under lawful contract or otherwise.

Please note that any information that is freely available or accessible in the 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 information.

3. PURPOSE

FlipTree shall collect and use Information for legitimate business purposes in order:

• That a visitor may download product information, order products and take advantage of certain other features of the Website;
• To provide information or interactive services through this Website, to the visitor's e-mail address or, where the visitor wishes it to be sent by post, to the visitor's postal address;
• To seek the visitor's feedback or to contact the visitor in relation to the services offered on FlipTree's website;
• To administer or otherwise carry out FlipTree's obligations in relation to any agreement that the visitor may have with FlipTree;
• To anticipate and resolve problems with any goods or services supplied to the visitor;
• To create products or services that may meet the visitor's needs;
• To process and respond to requests, improve FlipTree's operations, and communicate with visitor/s about FlipTree's products, services and businesses; and
• To allow the visitor to subscribe to FlipTree's news alerts.

4. COLLECTION OF INFORMATION

Only minimum Information required to meet the purposes mentioned in this policy shall be collected from the visitor/s. Neither FlipTree nor its representatives shall be responsible for the authenticity of such Information provided by the visitor/s. As a normal business practice, FlipTree may collect Information in order to enable secure online authentication, interaction and transaction with natural persons. This may include the installation of cookies and the collection of other session data.

5. ACCESS, CORRECTION OF INFORMATION AND WITHDRAWAL OF CONSENT

Any modifications/corrections required to the Information can be carried out on the website. In the event the visitor is unable to do so due to lack of functionality in FlipTree's website and/or the visitor wants to withdraw his/her consent to provide SPDI, he/she may contact the Grievance Officer, the details whereof are provided in clause 8 of this policy.

6. RETENTION, PROCESSING AND STORAGE OF INFORMATION:

6.1 FlipTree shall retain Information for only as long as necessary to meet legal or regulatory requirements or for legitimate business purposes as mentioned in this policy.

6.2 FlipTree has implemented required security practices and standards in line with the global standards and has a comprehensive documented information security program and policy in place, which contains managerial, technical, operational and physical security control measures that commensurate with the information assets being protected with FlipTree's nature of business. It is being reviewed periodically to keep pace with business, technology and regulatory changes.

7. DISCLOSURE OF INFORMATION

7.1 FlipTree shall not use or disclose Information for purposes other than as mentioned in this policy, except with the consent of the visitor providing such Information or as required by law. However, FlipTree may be legally required to disclose the Information in the following cases:

• Where the disclosure is necessary for compliance with a legal obligation;
• Where mandated under the law by government agencies to disclose such Information.

7.2 Where necessary, FlipTree may disclose Information to business partners or third parties during the normal course of business for the purposes mentioned in this policy. In such cases, FlipTree will only share Information related data when FlipTree is assured that:

• The Information is processed legitimately and appropriately by the business partner or third party in line with the established consent or in line with legal requirements.
• The business partner or third party has adopted a reasonable and equivalent level of security practices and procedures to ensure the security of the Information shared.

8. FEEDBACK OR CONCERN

For feedback or concern, if any, you may contact our Grievance Officer Mr. Shanu V Shaji by sending an email to grievance@fliptreetechnologies.com .

9. USE OF INFORMATION

Your Personal Information will be kept confidential to the maximum possible extent and will be used to support your relationship with us, to notify you of any updated information and new activities and other related functions offered by us. Any personally identifiable information provided by you will not be considered sensitive if it is freely available and/or accessible in the public domain. Further, any comments, messages, blogs, scribbles etc. posted/uploaded/conveyed/communicated by users on the public sections of the Application becomes published content and is not considered personally identifiable information subject to this Policy.

We may use Personal Information to verify whether you are entitled to access and use the products and services (each an "Application" and, collectively, the "Applications") made available to you by FlipTree. This Personal Information may also be used to enable us to enhance your experience of the Applications.

Further, with respect to Non-Personal Information automatically collected and stored in files, we use this information to understand and analyze trends, to administer the Applications, to learn about user behavior on the Applications, and to gather demographic information about the user base as a whole. We may use this information in its marketing and advertising services. We may also use such information to measure traffic patterns on the Applications.

CHANGES TO THIS POLICY

This Policy is current as of the Effective Date set forth above. FlipTree may, in its sole and absolute discretion, change this Policy at any time to the extent permitted by law. FlipTree will post its updated Policy on the Website, and update the Policy Effective Date. FlipTree encourages you to review this Policy regularly for any changes. Your continued access to or use of the Website after such posting will constitute your acceptance of such changes. IF YOU DO NOT AGREE, YOU MAY NOT ACCESS OR USE THE WEBSITE. If you have questions or concerns about this Policy, please contact us at privacy@fliptreetechnologies.com .