DATA PROTECTION & DATA PRIVACY

For the purpose of performing its obligations for the provided service, Fineoteric Consulting LLP (FCLLP) will be required to obtain data from the Customer, which shall be used by FCLLP for processing. FCLLP is committed to maintaining the confidentiality, integrity and security of data and information about the Customer.

PRIVACY OF DATA

FCLLP will not sell or rent the Customer’s confidential information to any other Party, for any reason, at any time. FCLLP uses and discloses the Customer’s information as follows:

• To facilitate the processing of the transaction
• To analyze FCLLP usage and improve the Service;
• To deliver to the Customer any administrative notices, money alerts and communications relevant to the Customer’s use of the Service;
• To fulfill the Customer’s requests for certain products and services;
• To third-party contractors that provide services to FCLLP and are bound by these same privacy restrictions;
• To provide payment history information to the bank/financial institution providing financing or to a Credit Bureau established under the rules and regulations of the country.
• To enforce FCLLP’s Terms of Use; and
• as otherwise set forth in this Privacy and Security Policy.

LIMITATION OF COLLECTON AND USE OF INFORMATION

Features of the FCLLP Service may require registration, which involves provision to FCLLP of an email address, a password and the Customer’s pin code (collectively the “Registration Information”). In order to benefit from the full functionality of the Service, the Customer may also need to provide the Customer’s relevant account credentials (“Account Credentials”) to allow FCLLP to access the status of the fulfillment of Transactions (“Account Information”) for the purpose of transaction processing.

The transaction information including Customer data is strictly restricted to FCLLP employees and contractors, as needed, and in accordance with specific internal procedures and safeguard governing access, in order to operate, develop or improve the Service. These individuals have been selected in accordance with FCLLP’s security policies and practices and are bound by confidentiality obligations. They may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

CHANGES TO CUSTOMER’S REGISTRATION INFORMATION

If the Customer’s Registration Information changes during the Customer’s subscription to FCLLP, the Customer may update it any time via the Service.

ONLINE SESSION INFORMATION AND USE IS ONLY USED TO IMPROVE THE CUSTOMER’S EXPERIENCE

When the Customer visits FCLLP, FCLLP may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on FCLLP. This information may be used, for example, to alert the Customer to software compatibility issues, or it may be analyzed to improve FCLLP design and functionality.

“Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by the Customer’s web browser on the Customer’s computer’s hard drive. FCLLP may set and access cookies on the Customer’s computer to track and store preferential information about the Customer. FCLLP may gather information about the Customer through cookie technology. For example, FCLLP may assign a cookie to the Customer, to limit the amount of times the Customer see particular information or to help better determine which information or preference settings to serve to the Customer. Please note that most Internet browsers will allow the Customer to stop cookies from being stored on the Customer’s computer and to delete cookies stored on the Customer’s computer. If the Customer or other users choose to eliminate cookies, the full functionality of the Service may be impaired for the Customer.

FCLLP’s cookies are encrypted so that only FCLLP can interpret the information stored in them.

Third party cookies: The Website allows cookies of social plugins of several third parties. This enables a user to share content of the Website on certain social networks. These plugins also enhance the user friendliness of the Website. For example, with the Facebook plugin on the Website, users can simply register themselves on the Website with their Facebook account details. The (use of the) data collected by these third parties via the social plugins are exclusively determined by such third party as FCLLP cannot read these cookies (nor can these parties read the cookies of FCLLP). For information regarding the third party cookies, please read the respective third party’s policies.

Web beacons are images embedded in a web page or email for the purpose of measuring and analyzing site usage and activity. FCLLP, or third party service providers acting on FCLLP’s behalf, may use web beacons to help us analyze Site usage and improve the Service.

FCLLP may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of FCLLP’s online campaigns or analyze visitor activity on FCLLP. FCLLP may permit these service providers to use cookies and other technologies to perform these services for FCLLP. FCLLP does not share any personal information about FCLLP’s customers with these third party service providers, and these service providers do not collect such information on FCLLP’s behalf. FCLLP’s third party service providers are required to comply fully with this Privacy

DISCLOSURE OF CUSTOMER’S INFORMATION TO PROTECT FCLLP’S RIGHTS OR IF REQUIRED BY LAW

Notwithstanding the foregoing, FCLLP reserves the right (and the Customer authorizes FCLLP) to share or disclose the Customer’s personal information when FCLLP determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:

• To enforce FCLLP’s rights against the Customer or in connection with a breach by the Customer of this Privacy and Security Policy or FCLLP’s Terms of Use;
• To prevent prohibited or illegal activities; or
• When required by any applicable law, rule regulation, subpoena or other legal process.

THE CUSTOMER’S DATA MAY BE TRANSFERRED UPON ACQUISITION OF FCLLP BUT ONLY IN ACCORDANCE WITH THIS POLICY

Credential information may, with prior intimation to the Customer and upon its authorization, such authorization not to be unreasonably withheld, be transferred to a third party as a result of a sale, acquisition, merger, re-organization or other transfer (a “Transfer”) involving FCLLP, to continue processing of transactions. Should such a Transfer occur, FCLLP will use its best efforts to require that the new combined entity follow this Privacy and Security Policy with respect to the Customer’s personal information, as and to the extent required by applicable law and to require that the Customer receive prior notice if the Customer Data could be used contrary to this Policy. Pending authorization from the bank/financial institution for such a transfer of Credential Information, the Customer accepts that there could be disruption to services delivered by FCLLP.

THE CUSTOMER CAN TRANSPORT OR DELETE ITS DATA

The Customer’s data belongs to the Customer. The Customer can remove it anytime the Customer wants. When the Customer requests FCLLP to delete the Customer’s account for the Service, the Customer’s data will be permanently expunged from FCLLP’s primary production servers and further access to the Customer’s account will not be possible. FCLLP will also promptly disconnect any connection FCLLP had established to the Customer’s Account Information and delete all account credentials. However, anoymized data, consisting of aggregate data derived from the Customer’s Account Information, may remain on FCLLP’s production servers indefinitely. The Customer’s data may also remain on a backup server or media. FCLLP keeps these backups to ensure FCLLP’s continued ability to provide the Service to the Customer in the event of malfunction or damage to FCLLP’s primary production servers.FCLLP will also keep the audit data on its servers from a compliance perspective.

Email Communication from FCLLP

FCLLP may allow Companies to subscribe to email newsletters and from time to time may transmit emails promoting FCLLP.

FCLLP subscribers have the ability to opt-out of receiving FCLLP’s promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts.

SECURITY OF CUSTOMER’S DATA

FCLLP uses a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of the Customer’s online session and to protect accounts and systems from unauthorized access.

When the Customer registers for the Service, FCLLP requires a password from the Customer for the Customer’s privacy and security. FCLLP uses industry-standard 128 bit secure socket layer (SSL) encryption to protect data transmissions between the Customer’s browser and FCLLP’s servers, such as the Customer’s Registration Information for FCLLP or Account Credentials.

FCLLP’s servers may be based in a secure third party facility. FCLLP’s databases are protected from general employee access both physically and logically. FCLLP may store a salted digest for the Customer’s Service password so that the Customer’s password cannot be recovered even by FCLLP. All backup drives and tapes are encrypted.

However, it is important to understand that these precautions apply only to FCLLP’s Site and systems. While FCLLP will have contractual agreements with third parties around data security, FCLLP exercises no control over how the Customer’s information is stored, maintained or displayed by third parties or on third-party sites.

FCLLP’S SERVICE ENSURES SECURE COMMUNICATION WITH ENCRYPTION

From the time the Customer submits the Customer’s Login ID and Password, these communications between the Customer’s computer and FCLLP are encrypted using Secure Sockets Layer (SSL3) technology. SSL enables Customer and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery.

IN THE EVENT OF A SECURITY BREACH

FCLLP uses stringent security measures to prevent loss, misuse or alteration of information under our control. If any user has sufficient reason to believe that their data has been compromised or there has been a breach of security, you may write to us immediately on the contact details given in this policy so that we may take suitable measures to either rectify the breach and inform the concerned authorities if need be.

THE CUSTOMER IS RESPONSIBLE FOR MAINTAINING CONFIDENTIALITY OF THE CUSTOMER’S LOGIN ID AND PASSWORD

FCLLP maintains strict rules to help prevent others from guessing the Customer’s password. FCLLP also recommends that the Customer change the Customer’s password periodically. The Customer is responsible for maintaining the security of the Customer’s Login ID and Password. The Customer may not provide these credentials to any third party. If the Customer believes that they have been stolen or been made known to others, the Customer must contact FCLLP immediately, but in any event the Customer should change the Customer’s password immediately via the Service. FCLLP is not responsible if someone else accesses the Customer’s account through Registration Information they have obtained from the Customer or through a violation by the Customer of this Privacy and Security Policy or FCLLP’s Terms of Service.

If the Customer has a security related concern, it should contact FCLLP. FCLLP will work closely with the Customer to ensure a rapid and personal response to the Customer’s concerns.

FCLLP POSTS UPDATES ON FCLLP WHENEVER THERE IS A CHANGE TO FCLLP’S PRIVACY AND SECURITY POLICY

FCLLP updates this Privacy & Security Policy periodically. Customer will be provided notice of any such modification by electronic mail or by publishing the changes on the website. By accessing FCLLP’s website and using its service, you hereby declare that you have read the privacy policy and agreed to its contents.