Privacy policy

LAST UPDATED: 11 November 2022

This Privacy Policy (“Policy”) outlines VERVE PAYMENT SERVICES PROVIDER CO LLC (“Urban Ledger”, “we” or “us”) practice in relation to the storage, use, processing, and disclosure of personal data that you have chosen to share with us when you access our website https://geturbanledger.com and mobile application “Urban Ledger” (collectively, the “Platform"), or personal data that we may have access to in relation to your use of the Services.

The App/Site (i) provides an online digital ledger book / CRM, Payment, Collections and Reminders wherein the Users, can record their ledger entries with their respective customers and (ii) also allows Users to generate a payment link which can be sent it to their respective customers and the customers could use the payment link and make the payment of the amount to the Users in settlement of their obligations towards the Users (collectively, “Services”). Please note that ‘Services’ would include any other future services we may provide or propose to provide.

At Urban Ledger, we are committed to protecting your personal data and respecting your privacy. Please read the following terms of the Policy carefully to understand our practices regarding your personal data and how we will treat it. This policy sets out the basis on which any personal data we collect from you, we collect about you, or that you provide to us, will be processed by us. If You provide us with personal information about someone else, You confirm that they are aware that You have provided their information and that they consent to our use of their information according to our Privacy Policy.

Capitalised words in the Policy shall have the same meaning ascribed to them in the Terms and Conditions (“Terms”), available at Terms & Conditions. Please read this Policy in consonance with the Terms.

1. THE DATA WE COLLECT ABOUT YOU
   1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed – for example, anonymous data.
   2. Urban Ledger may supplement the information provided by You with information from third parties and add it to the information provided by You.
   3. We may collect, use, store and transfer different kinds of personal data about you to provide you with or in connection with the Services. Such personal data includes:
      1. data pertaining to your identity and profile-related data, such as your first and last name, profile image, username or similar identifiers, gender, title, passwords, purchases or orders, feedback, survey responses, etc.;
      2. contact details, including email addresses, phone numbers, delivery addresses, business addresses, etc.;
      3. transaction data, including details about payments to and from you and details of products and services you have purchased or sold;
      4. technical data includes IP addresses, browser types and versions, time zone settings and locations, operating systems, and other technology on the devices you use to access the platform;
      5. usage data including information about how you use our Services; and
      6. marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
      7. KYC Data - We may retrieve from Your records available with third party including from Know Your Customer (KYC) Registration Agency (KRA) such as name, KYC details, KYC status, father’s/spouse’s name, occupation, address details and other related documents, for completion of Your KYC, which is required by the financial institutions for processing of Your application for availing a financial product.
      8. Other Information - We may also request You to provide other information as and when necessary, subject to your consent.
   4. We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under applicable laws. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the Services.
   5. Urban Ledger may use the personal information and transaction data collected to provide, maintain, improve, analyze and personalize the Services to its Users, partners and third party providers. More specifically, Urban Ledger may use such information to:
      1. Categorise customers into different risk profiles, and create insights and summaries, the logic of which can be solely decided by Urban Ledger.
      2. We can distribute these insights and summaries via Urban Ledger app, web portal, telephonic calls, text messages, WhatsApp, email, or other electronic mediums
   6. Where we need to collect personal data by law, or under the terms of the arrangement we have with you, and you fail to provide that data when requested, we may not be able to perform our obligations under the arrangement we have with you or are trying to enter into with you (for example, to provide you with features of the Services). In this case, we may have to cancel or limit your access to the Services, but we will notify you if this is the case at the time.
2. HOW DO WE COLLECT DATA ABOUT YOU?
   1. We use different methods to collect and process data about you.
      1. Information you give us – This is the information (including identity, contact, and marketing and communications data) you consent to giving us about you when you create a Profile or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Services, use an in-Platform feature, or share data through the Services, through other activities commonly carried out in connection with the Services, and when you report a problem with the Platform and our Services. If you contact us, we will keep a record of the information shared during the correspondence.
      2. Information that you authorise a user of the Services to share with us – We may collect data and information about you that you authorise a merchant or supplier of goods or services you have sought or purchased, or intend to seek or purchase, to share with us.
      3. Information we collect about you and your device – Each time you visit our Platform or use one of our Services, we will automatically collect personal data including device and usage data. We collect this data using cookies and other similar technologies.
      4. Information we receive from other sources including third parties and publicly available sources - We will receive personal data about you from various third parties and public sources as set out below:
         1. Analytics providers such as Google and Facebook;
         2. Advertising networks;
         3. Search information providers;
         4. Contact, financial and transaction data from providers of technical, payment, and delivery services;
         5. Identity and contact data from data brokers or aggregators; and
         6. Identity and contact data from publicly available sources.
      5. Information automatically tracked while using the App or Site
         1. Credit/Payment Records: We store all your credit/payment records in a cloud-based environment using the services of third party infrastructure service providers.
         2. Customer Information: We store the contact information of your customers. We also keep a log of all the credit/payment related communication to the customers.
         3. Demographic and Related Information: We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track the User behaviour on Site.
         4. Log File Information: Our Servers automatically collect limited Information about your device's connection to the internet, including your IP address, when you visit our Site or use the App. We automatically receive and log Information from the App and/or your browser including but not limited to IP address, your device or computer's name, and your operating system, We may also collect log Information from your device, including but not limited to your location, IP address, your device's name, device's serial number or unique identification number (e.g. UDID on your iOS device, Android ID or ADID on your Android Device), your device operating system, browser type and version, CPU speed, and connection speed etc.
         5. Cookies: To improve the responsiveness of the Site for our Users, we may use "cookies", or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (User ID) to understand the User's individual interests using the identified computer. By continuing to visit the App/Site, you are agreeing to the use of cookies and similar technologies for the purposes we describe in this Policy. If you prefer not to receive cookies or web beacons, then you should stop using Services, or consult your browsing and third party cookie settings. We use cookies and other technologies for analysing and optimising our websites as well as for marketing purposes. Our partners may also assign their own cookies to your browser, a process that we do not control.
         6. Link to third-party SDK - The App could hav a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third-party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data. Our third-party service provider employs separation of environments and segregation of duties and has strict role-based access control on a documented, authorized, need- to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data. Furthermore, our registered third party service provider provides hosting security – they use industry- leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions
3. HOW DO WE USE AND DISCLOSE DATA WE COLLECT?
   1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to provide you with the Services, or where we need to comply with a legal obligation.
   2. You understand that when you consent to providing us with your personal data, you also consent to us sharing the same with third parties. You are aware that by using our Services or creating an account on the Platform, you authorise us, our associate partners, and affiliates to contact you via email, phone, or otherwise. This is to ensure that you are aware of all the features of the Services.
   3. You are aware that any and all information pertaining to you, whether or not you directly provide it to us (via the Services or otherwise), including but not limited to personal correspondence such as emails, instructions from you etc., may be collected, compiled and shared by us in order to render Services to you and you expressly authorise us to do so. This may include but not be limited to storage providers, payments systems providers, marketing partners, data analytics providers, and consultants, lawyers, and auditors. We may also share this information with our parent company, subsidiaries, affiliates or any of their holding companies.
   4. You agree and acknowledge that we may share data without your consent, when it is required by law or by any court or government agency or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or the Terms, or in order to comply with any applicable laws and regulations.
   5. In general, we will not disclose personal data except in accordance with the following purpose/activity:
      1. To install the Platform and register you as a user;
      2. To deliver Services;
      3. To manage our relationship with you including notifying you of changes to any Services;
      4. To administer and protect our business and the Services including troubleshooting, data analysis and system testing;
      5. To deliver content and advertisements to you;
      6. To make recommendations to you about goods or services which may interest you;
      7. To measure and analyse the effectiveness of the advertising we serve you;
      8. To monitor trends so we can improve the Services;
      9. To perform our obligations that arise out of the arrangement we are about to enter or have entered with you;
      10. To enforce our Terms;
      11. 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;
      12. To comply with a legal or regulatory obligation.
   6. You authorise us to send you electronic alerts and messages for details pertaining to registration on the Platform, requirements arising out of the provision of Services, and advertising.
   7. We may also present information related to credit records, User spends, User payment info, credit score (with user consent), app interactions, in-app search history, patterns and User data tracked by us only in the form of aggregated statistics on data such as overall app usage by date, time, balances, etc. within our App/Site or to our partners.
   8. Further, you agree to receive promotional and other emails and other forms of communication from us. Through such communication you will receive information about the latest developments on the Services. You may unsubscribe from our mailing list at any time, via the unsubscribe option we offer.
4. TRANSFER OF PERSONAL DATA
   1. As a part of your use of the Services, the information and personal data you provide to us may be transferred to and stored at countries other than India. This may happen if any of our servers are from time to time located in a country other than India, or one of our service providers is located in a country other than India. We may also share information with entities of countries other than India. These countries shall be subject to data laws of their respective countries.
   2. If you use the Services while you are outside India, your information may be transferred to a country other than India in order to provide you with the Services.
   3. By submitting your information and personal data to us, you agree to the transfer, storage, and/or processing of such information and personal data outside India in the manner described above.
5. THIRD PARTY LINKS AND USER EXPERIENCE IMPROVEMENT SERVICES
   1. Our Services may, from time to time, contain services provided by or links to and from the websites of our partner networks, advertisers and affiliates (“Third Party Services”). Please note that the Third Party Services, that may be accessible through our Services have their own privacy policies. We do not accept any responsibility or liability for the policies or for any personal data that may be collected through the Third Party Services. Please check their policies before you submit any personal data to such websites or use their services.
   2. We use third-party user experience improvement services (including but not limited to those provided by Google Inc and/or its affiliates) and applications to better understand your behavior on the Services.
   3. The information collected includes (but is not limited to):
      1. age;
      2. gender;
      3. preferences; and
      4. interests.
   4. Your relationship with these third parties and their services and tools is independent of your relationship with us. These third parties may allow you to permit/restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.
   5. The place of processing information depends on each third-party service provider and you may wish to check the privacy policy of each of the service providers to identify the data shared and its purpose. You will be subject to a third party’s privacy policy if you opt in to receive communications from third parties. We will not be responsible for the privacy standards and practices of third parties
   6. Collection of financial sms information- We don’t collect, read or store your personal SMS from your inbox. We may collect and monitor only financial SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various bank accounts that you may be holding, cash flow patterns, description and amount of the transactions undertaken by you as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis. This process will enable you to take financial facilities from the regulated financial entities available on the Platform in the future. This Financial SMS data also includes your historical data.
6. COOKIES
   1. We use cookies and/or other tracking technologies to distinguish you from other users of the Services and to remember your preferences. This helps us to provide you with a good experience when you use our Services and also allows us to improve the Services.
   2. We collect data by way of ‘cookies’. Cookies are small data files which are sent to your browser from the Platform and are stored on your computer or device (hard drive). The cookies shall not provide access to data in your computer or device such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow us to administer the Services and provide you with a tailored and user-friendly service. The cookies shall enable you to access certain features of the Services. Most web browsers and devices can be set to notify when you receive a cookie or prevent cookies from being sent. If you do prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform or try to access some of the Services.
   3. Additionally, you may encounter cookies or other similar devices on certain pages of the Services that are placed by third parties. We do not control the use of cookies by third parties. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities in relation to the Services, we may collect such information into a file specific to you.
7. DATA SECURITY
   1. We implement certain security measures including encryption, firewalls, and socket layer technology to protect your personal information from unauthorised access and such security measures are in compliance with the security practices and procedures as prescribed under the Information Technology Act, 2000 and the applicable rules (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information Rules, 2011). However, you agree and acknowledge that the above-mentioned measures do not guarantee absolute protection to the personal information and by accessing the Services, you agree to assume all risks associated with disclosure of personal information arising due to breach of firewalls and secure server software.
   2. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
   3. We will comply with the requirements under the Information Technology Act, 2000 and the rules made thereunder in the event of a data or security risk.
8. DATA RETENTION
   1. You are aware that your personal data will continue to be stored and retained by us for a reasonable period after termination of your account on the Platform.
9. BUSINESS TRANSITIONS
   1. You are aware that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.
10. CHANGE IN PRIVACY POLICY
    1. We keep our Policy under regular review and may amend this Policy from time to time, at our sole discretion.
    2. The terms of this Policy may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email. The new Policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Services.
    3. Your continued use of the Services shall constitute consent to the latest policy.
11. GRIEVANCE OFFICER

    You may contact us at [email protected] with any enquiry relating to this Policy or an enquiry relating to your personal information (including reviewing or updating)