Privacy Policy

1. Introduction

  • The mobile application called ‘Punyam’ (“App”), a company incorporated under the provisions of the Companies Act, 2013 and (hereinafter referred to as “Punyam” or “We” or “Us” which expression shall, unless it is repugnant to the context or meaning thereof, be deemed to include its successors, affiliates, and permitted assigns).
  • Punyam is committed to respecting your online privacy and recognizes your need for appropriate protection and management of any information you share with Punyam on the App. This privacy policy (“Policy”) explains how Punyam will collect, use, share and process information about the services provided on the App.
  • This Policy is being framed given the Information Technology Act, 2000 read with Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and Regulation 3(1) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
  • By accepting this Policy, you understand and agree to the collection, use, sharing, and processing of personal information as described herein.

2. Scope

  • This Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder. This Policy does not require any physical, electronic, or digital signature.
  • By accessing or using the App or giving us your information or otherwise clicking to accept this Policy, if and when prompted on the App, you undertake that you can enter into a legally binding contract video. This Policy, constitutes a legally binding document between you and Punyam under applicable law, in particular, the Indian Contract Act, 1872. Punyam will collect and process your personal and third-party data carefully, only for the purposes described in this Policy and only to the extent necessary as defined therein and within the scope of the applicable legal regulations. This Policy seeks to ensure that any personal information or third-party information handled by Punyam is managed in a way that is ethical, compliant, and adheres to best industry practices.
  • Please read the terms and conditions of this Policy carefully, before accessing or using the App or otherwise clicking to accept this Policy, if and when prompted on the App. By accessing or using the App including its services or otherwise clicking to accept this Policy, if and when prompted on the App, you agree to the terms of this Policy.
  • This Policy describes the types of information Punyam collects, why and how Punyam uses the information, with whom Punyam shares it, and the choices you can make about Punyam’s use of the information. This Policy also describes the measures Punyam takes to protect the security of the information and how you can contact Punyam about its privacy practices.
  • This Policy describes Punyam’s current data protection policies and practices and may be amended/updated from time to time. Punyam will notify you at least once a year, or whenever there is a change in the Policy, by email or by posting a conspicuous notice on the App regarding its then-applicable data protection policies. The Policy shall come to effect from the date of such update, change, or modification. It is recommended that you regularly check this Policy to apprise yourself of any updates. Your continued use of the App or provision of data or information thereafter will imply your unconditional acceptance of such updates to this Policy.

4. Types of Information

  • Personal Information is defined as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
  • Personal Information: Personal Information means any information that may be used to identify an individual, including, but not limited to, the first and last names, telephone number, e-mail address, or any other contact information, date of birth, age, gender, or any other information, an image of yourself, date, time and place of birth, official identifiers like PAN and Aadhar Card , financial information including bank account details, credit/debit card details or such other payment information (hereinafter referred to as “Personal Information”). Further, Sensitive Personal Data or Information (“SPDI”) of a person includes Personal Information about that person relating to passwords, financial information (bank accounts, credit and debit cards, or other payment instruments), and physical information. Punyam limits the collection of Personal Information (including, SPDI) to that which is necessary for its intended purpose.
  • Non-Personal Information: Non-personal information means information that does not specifically identify an individual, but includes information from you, such as your browser type, your Internet Service Provider (ISP), operating system, and your Internet Protocol (IP) address. Punyam may gather any non-personal information regarding how many people visit the App, their IP address, browser types and versions, time zone settings and locations, operating systems, applications installed on your device, device ID, device manufacturer and type, device, connection information, screen resolution, usage statistics, default communication applications and other technology on the devices you use to access the App, and shall include all such Personal Information collected and stored by Punyam that undergoes the process of de-identification and is no more identifiable to you or any natural person (hereinafter referred to as “Non-Personal Information”). Punyam may also collect Non-Personal Information that you voluntarily provide, such as information included in response to a questionnaire or a survey conducted by Punyam.
  • Usage Information: Usage Information includes without limitation all data and information collected automatically through the App (or through the third-party analytics service providers), by use and access of the App like system administrative data, statistical and demographical data, and operational information and data generated by or characterizing use of the App including without limitation Non-Personal Information, cookies, App traffic, time spent on the App, number of visits to the App and other similar information and behavior indicating the mode and manner of use of the App (hereinafter referred to as the “Usage Information”).
  • Personal Information, SPDI, Non-Personal Information, and Usage Information hereinafter shall be referred to as “Information”.

5. Collection of Information

  • Punyam may collect information from you when you (a) register on the App; (b) update or change personal details in your account; (c) use the App for providing/ availing any Services (as applicable and as defined in the EULA applicable to you) being provided; (d) voluntarily participate in campaigns conducted by Punyam on the App or respond to questionnaires published by Punyam on the App (if any); (e) voluntarily complete a survey or provide feedback about the services provided on the App; and (f) carry out any other transactions on the App.
  • You hereby acknowledge and agree that all information is provided by you to Punyam voluntarily and the Information provided by you is not subject to any undue influence.
  • Punyam may use cookies to monitor the App usage including, without limitation, to provide useful features to simplify your experience when you return to the App, like remembering your login id and delivering relevant content based on your preferences, usage patterns, and location.
  • Punyam may also collect Non-Personal Information based on your browsing activity and about your use or access to the App like your Internet Protocol address, your Operating System, your prior search results, etc., which may or may not be publicly accessible.
  • Information collected by Punyam from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.
  • You may use the App without providing Punyam any Information about yourself. However, you may not be able to access certain services on the App in case you choose to do so.

6. Use of Information

  • Punyam uses the Information you provide to (a) manage your account; (b) fulfill your requests for the services offered on the App; (c) respond to your inquiries about its offerings and the transactions carried out on the App; (d) provide you with information about services available on the App and offer you other products and services that Punyam believes may be of interest to you; (e) resolve any glitches on the App including addressing any technical problems; (f) improve the services and content on the App and your experience of navigating through the App and carrying out transactions on the App; and (g) manage Punyam ’s relationship with you.
  • Punyam may use the information to monitor your use of the services and may review and analyze the Information provided by you to provide you with customized service.
  • Punyam may use your Non-Personal Information or Usage Information for internal business purposes, such as data analysis, research, developing new products and/or features, enhancing and improving existing products and services, and identifying usage trends.
  • Subject to and by applicable laws, Punyam has the right to use your Information to conduct promotional/marketing-related activities on the App, including but not limited to, using your Personal Information for making posters/banners to promote Punyam ’s services.
  • When you send an email message or otherwise contact Punyam through the App, Punyam may use the Information provided by you to respond to your communication by way of messages on the App, Short Message Service (SMS), email, or any other communication channels that Punyam may deem fit. Punyam may also archive such Information and/or use it for future communications with you to inform you regarding updates, newsletters, offers, new services, and promotions.

7. Information Sharing

  • Punyam maintains your Information in electronic form on its devices and on the equipment of Punyam's employees. The Information is made accessible to employees, agents or partners, and third-parties only on a need-to-know basis.
  • Punyam does not rent, sell, or share Information with other people or with other non-affiliated entities, except with your consent or to provide services you have requested for or under the following circumstances:
  • Punyam may engage third-party vendors and/or contractors to perform certain support services, who may have limited access to Information.
  • To process your transactions, Punyam may direct you to a payment gateway service provider of its own choice, which may have access to the Information provided by you while making such payment.
  • Punyam may rent, sell or share Non-Personal Information or Personal Information in an aggregate form after it undergoes the process of de-identifications and is no more identifiable to you, with any third party.
  • Punyam may share Information with government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise legal rights; to defend against legal claims; or as otherwise required by law. This may be done in response to a law enforcement agency's request.

8. Third Party Service Providers

  • Punyam may engage other third-party vendors and/or contractors to perform certain support services, including, without limitation, fulfillment of your service requests, software maintenance services, advertising, and marketing services, web hosting services, and such other related services which are required by Punyam to provide its services efficiently. These third parties may have limited access to Information. If they do, this limited access is provided so that they may perform these tasks for Punyam and they are not authorized by Punyam to otherwise use or disclose Information, except to the extent required by law. Punyam does not make any representations concerning the privacy practices or policies or terms of use of such websites, nor does it control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Punyam of the website, the website's provider, or the information on such website.
  • The App may contain links and interactive functionality interacting with the websites of third parties. Punyam is not responsible for and has no liability for the functionality, actions, inactions, privacy settings, privacy policies, terms, or content of any such websites. Before enabling any sharing functions to communicate with any such websites or otherwise visiting any such websites, Punyam strongly recommends that you review and understand the terms and conditions, privacy policies, settings, and information-sharing functions of each such third-party website.

9. Disclosure to Acquirers

  • Punyam may disclose and/or transfer information to an investor, acquirer, assignee, or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of Punyam’s equity, business, or assets.

10. Control Over Your Personal Information

  • You have the right to withdraw your consent at any point, provided such withdrawal of the consent is intimated to Punyam . If you at any time wish to rectify your Personal Information including financial information, you may write to Punyam as per paragraph 11 of this Policy.
  • Once you withdraw your consent to share the Personal Information, collected by Punyam and/or delete/deactivate your Account (as applicable), Punyam shall have the option not to fulfill the purposes for which the said Personal Information was sought and Punyam may restrict you from using the services on the App and/or the App itself.
  • If you wish to delete your account, and thereby discontinue using the services provided by Punyam on the App, you may do so at any time, in accordance with the EULA applicable to you. In other cases, you may discontinue using the services provided by Punyam on the App by writing to Punyam.

11. Rectification/Correction of Personal Information

  • You shall have the right to review your Personal Information, including SPDI (as applicable) submitted by you on the App, and to modify or delete any Personal Information or SPDI provided by you directly on the App. You hereby understand that any such modification or deletion may affect your ability to use the App. Further, it may affect Punyam's ability to provide its services to you.
  • Punyam reserves the right to verify and authenticate your identity and your account information and/or payment information to ensure accurate delivery of services through the App. Access to or correction, updating, or deletion of your Personal Information and/or SPDI (as the case may be) may be denied or limited by Punyam if it would violate another person's rights and/or is not otherwise permitted by applicable law.
  • If you need to update or correct your Personal Information that Punyam may have collected to offer you personalized services and offers, you may send updates and corrections to Punyam at customer care citing the reason for such rectification of Personal Information. Punyam will take all reasonable efforts to incorporate the changes within a reasonable period.

12. Term of Storage of Personal Information

  • Punyam shall store your Personal Information at least for such period as may be required and permitted by law or for a period necessary to satisfy the purpose for which the Personal Information has been collected. These periods vary depending on the nature of the information and your interactions with Punyam.
  • Punyam may store Non-Personal Information and Usage Information received from you till such time it requires provided such storage and retention is in accordance with applicable law.
  • You agree that you will not submit any false information or any illegal or damaging content to the App.
  • Punyam reserves the right to terminate access to or the ability to interact with the App in response to any concerns Punyam may have about false, illegal, or damaging content, or for any other reason, in its sole discretion.

13. Cookies

  • Punyam uses cookies and/or other tracking technologies to distinguish you from other users of the services and to remember your preferences on the App. This helps Punyam to provide you with a good experience when you use the services on the App and also allows Punyam to improve such services. Cookies are text files Punyam places in your mobile phone, tablet, or other devices to store your preferences. Cookies, by themselves, do not tell Punyam your e-mail address or other personally identifiable information unless you choose to provide this information to Punyam by, for example, registering on the App. They are designed to hold a marginal amount of data specific to a particular user. However, once you choose to furnish the App with personally identifiable information, this information may be linked to the data stored in the cookie. Punyam uses cookies to understand App usage and to improve the content and offerings on the App. For example, Punyam may use cookies to personalize your experience on the App (e.g., to recognize you by name when you return to the App) and save your password in password-protected areas. Punyam may also use cookies to offer you products, programs, or services. Cookies may be placed on the App by third parties as well, the use of which Punyam does not control.
  • Session cookies are automatically deleted from your hard drive once a session ends, and most cookies are session cookies. You may decline the cookies, however, if you decline the cookies, you may be unable to use certain features on the App and you may be required to re-enter your password frequently. You may opt to leave the cookie turned on.

14. Protection of Information

  • Punyam has taken adequate measures to protect the security of Information and to ensure that your choices for its intended use are honored. Punyam takes robust precautions to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction.
  • Punyam considers the confidentiality and security of your information to be of utmost importance. It, therefore, uses industry standards, and physical, technical, and administrative security measures to keep information confidential and secure, and Punyam will not share your information with third parties, except as otherwise provided in this Policy. Please be advised that, however, while Punyam strives to protect Information and privacy, Punyam cannot guarantee or warrant its absolute security when Information is transmitted over the internet into the App. Punyam will periodically evaluate this necessity considering your privacy and our relationship while keeping the applicable legislation in mind.
  • Access to your account on the App is via. your Login Credentials, which are password protected and this helps to secure your account information. You are solely responsible for maintaining the confidentiality of your Login Credentials. To ensure the safety of your Information, you are advised against sharing your Login Credentials with anyone. If you suspect any unauthorized use of your account, you must immediately notify Punyam. You shall be liable to indemnify Punyam for any loss suffered by Punyam due to such unauthorized use of your account.
  • For any loss or theft of Information, due to unauthorized access to your device through which you use the App or other reasons solely attributable to you, Punyam shall not be held liable or responsible under any circumstance whatsoever. Further, Punyam shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond Punyam's reasonable control including but not limited to acts of government, computer hacking, unauthorized access to computer data and storage devices, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the user, etc.

15. Minor & Usage On Behalf Of Another Person

  • Punyam does not intend to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions. Punyam does not intentionally or knowingly collect Personal Information through the App from anyone under that age. Punyam encourages parents and guardians to be involved in the online activities of minors to ensure that no Personal Information is collected from a minor without their prior consent. If you are using the App on behalf of someone else, including but not limited to, on behalf of your minor child/children, you represent and warrant that you are authorized by such person to accept this Policy on their behalf and to consent on behalf of such person to Punyam's use of such person's Personal Information as described in this Policy.

16. Limitation of Liability

  • Punyam shall not be liable to you for any loss of profit, production, anticipated savings, goodwill or business opportunities or any type of direct or indirect, incidental, economic, compensatory, punitive, exemplary, or consequential losses arising out of performance or non-performance of its obligations under this Policy.
  • Punyam is not responsible for any actions or inactions of any third parties that receive your Information.
  • Notwithstanding anything contained in this Policy or elsewhere, Punyam shall not be held responsible for any loss, damage, or misuse of your Information, if such loss, damage, or misuse is attributable to a Force Majeure Event. The term “Force Majeure Event” shall mean any event that is beyond Punyam's reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, civil disturbances, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, pandemic or national/state lockdown due to any reason and any other similar events not within Punyam's control and which Punyam is not able to overcome.

17. Opt-Out

  • Once you register as a user on the App, you may receive communication, including but not limited to messages on the App, Short Message Service (SMS), and phone calls from Punyam on the registered mobile number and e-mails on your registered e-mail address (as applicable). These messages, e-mails, and calls (as applicable) could relate to your registration, transactions that you carry out through the App and promotions that are undertaken by Punyam. You have the option to 'opt-out' of all newsletters and other general email marketing communications from Punyam by way of links provided at the bottom of each mailer (as applicable). Punyam respects your privacy and if you choose to not receive such mailers, Punyam shall take all adequate steps to remove you from such lists. However, you will not be able to opt-out of receiving administrative messages, customer service responses, or other transactional communications.

18. Changes to this Policy

  • Punyam reserves the right to update, change or modify this Policy at any time, subject to the terms contained herein. The Policy shall come to effect from the date of such update, change, or modification.

19. Governing Law and Dispute Resolution

  • This Policy shall be governed by and interpreted and construed in accordance with the laws of India. The place of jurisdiction shall exclusively be in New Delhi, India. In the event of any dispute arising out of this Policy, the same shall be settled by binding arbitration conducted by a sole arbitrator, appointed jointly by both parties and governed by the Arbitration and Conciliation Act, 1996. The venue and seat of arbitration shall be New Delhi, India.

20. Grievance Redressal Mechanism

  • By the Information Technology Act, 2000 and Rules made thereunder, the name and contact details of the Grievance Officer are provided below:

    For registering your complaint, please write to the Grievance Officer at the above-mentioned email address about any violation of this Policy or the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. The Grievance Officer shall redress the complaint in accordance with the provisions of the Information Technology Act, 2000 and Rules made thereunder.

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