PRIVACY POLICY

1. GENERAL:

HSBE Limited, having its cooperate office at Lotus Villas Jalpura Villa No-197, Greator Noida west up gautam Buddha nagar uttar pradesh 201310,India (“HSBE”, “we”, “us” or “our”) is managing and operating the mobile application/website and tablet applications available at www.SHOPROPAY.com (collectively referred to as “SHOPROPAY”, “Website”, “App”), which inter alia facilitate the sale and purchase of products and services listed and sold on the Website (“Products”). The term “User” or “Users” or “you” or “your” means any individual or entity which uses, accesses or, browses the Website and/or purchases the Products.

SHOPROPAY is committed to protecting and respecting your privacy. This privacy policy (“Privacy Policy”) is to be read together with the terms of use (accessible here) (“Terms”) and all other policies notified by us from time to time. This Privacy Policy outlines SHOPROPAY’s privacy practices regarding the collection, use, disclosure, processing, transfer, storage, retention and safeguarding of the Information (defined hereinafter) provided to us by you through the Website and/or pursuant to the purchase of the Products.

2. APPLICABILITY OF POLICY:

By accessing, using, browsing, or purchasing on SHOPROPAY and/or by submission of Information (and in case of a minor - submission of your Information either by your parents or your guardian), you agree to be bound by the terms of this Privacy Policy and consent to the collection, storage, possession, dealing, handling, sharing, disclosure or transfer of your Information in accordance with the terms of the Privacy Policy and agree to be governed by the laws of India including but not limited to the laws applicable to data protection and privacy.

Please note we do not offer the Products under this App outside India, however, you may be able to access or browse the Website from outside the Republic of India. Your Information will primarily be stored and processed in India and may be governed by the applicable laws (including data protection laws) that are different from those that

We may collect a variety of information from you, including your name, mailing address, phone number, email address and contact preferences, including any other usage and interaction details with us or our affiliates. We may collect such information which when combined with other pieces of information available with us could reasonably allow you to be identified (“Personal Information”).

We may also collect, receive, process or store certain sensitive personal data or information provided by you which may consist of, but not be limited to

·         (a) Password;

·         (b) Financial information such as bank account or credit card or debit card or other payment instrument details;

·         (c) Any detail relating to (a) and (b) above as provided to us for providing Products; and

·         (d) Any of the information received under (a) and (b) above by us for processing or storing under lawful contract or otherwise.

(Collectively, referred to as “Sensitive Personal Data or Information”).

Personal Information and Sensitive Personal Information are collectively referred to as “Information”.

You may be asked to provide your Information anytime you visit, access, use or browse SHOPROPAY. We may share Information and use it in consistent with the provisions of this Privacy Policy. We may also combine it with other Information to provide and improve our Products, services, content and advertising.

SHOPROPAY is not directed towards minors. We do not knowingly collect Information from any User who is under 18 (Eighteen) years. If we are made aware that we have collected the Information of a person below the age of 18 (Eighteen) years, we will take steps to delete such Information within a reasonable time frame. If a parent or guardian becomes aware that his or her child has provided his/ her Information on SHOPROPAY without their consent, he or she shall contact us for the deletion of such Information. In the event, where in contravention to the Privacy Policy and Terms, a person below the age of 18 (Eighteen) uses the Products or accesses the Website, we shall not be held liable or responsible for any damage or injury suffered by such person.

4. USE OF INFORMATION COLLECTED:

The following is the manner in which we collect, use, share, and retain Information:.

Collection

We may collect Information, whenever relevant, to help provide you with information and to complete any transaction or display any Product you have requested or to participate in any event or contest. You also consent to the collection of certain Information or document as per the applicable laws in the course of your purchasing the Products.

Usage

The App seeks your Information to: (i) create and/or give you access to your registered account on the Website; (ii) validate and process your request for the provision of Products or accessing of the App; (iii) assist merchants to handle and fulfil your orders; (iv) develop, deliver, process and improve our Products in order to personalize and improve your experience; (v) inform you about our Products, offers, updates, upcoming events, including providing you information in relation to order confirmations, invoices, technical notices, security alerts; or (vi) facilitate our internal business operations, including the fulfilment of any legal and regulatory requirements; (vii) provide you with recommendation about Products you may be interested in, based on your use of the App; (viii) provide you with marketing communications and advertising that we believe may be of interest for you; (ix) resolve any request, disputes, grievance, or complaints by you in relation to your use of the Website; or (x) detect and protect us against error, fraud and other illegal activity. When you use our voice, image and camera services, we use your voice input, images, videos, and other Information to respond to your requests, provide the requested Products to you, and improve our services or the Website.

Sharing

We may disclose Information to our affiliates when necessary to perform services on our behalf or on your behalf, to provide display advertising and promotional services, providing search results and links (including paid listings and links), providing customer service etc. These affiliates may market to you as a result of such sharing unless you explicitly opt-out.

We may disclose Information to our trusted third-party service providers when necessary in order to facilitate the provision of our Products on the Website. We ensure that such third-party service providers are bound by reasonable confidentiality obligations; and/ or use, maintain and follow generally accepted industry and security standards commensurate with the security standards set forth in this Privacy Policy with respect to such Information

We may also share Information with external organizations or individuals if we believe that access, use, preservation or disclosure of the Information is reasonably necessary to:

·         (a) meet any applicable law, regulation, legal process or enforceable governmental request;

·         (b) detect, prevent or otherwise address fraud, security or technical issues;

·         (c) protect against harm to the rights, property or safety of our or our Users, or the public, to fight fraud and credit risk, as required or permitted by law.

We may also disclose or transfer your Information to any third party as a part of reorganization or a sale of the assets, division or transfer of a part or whole of us. We shall ensure that third party to which we transfer or sell our assets will have appropriate confidentiality and security measures, at least as protective as those described in this Privacy Policy, to handle your Information. You will have the opportunity to opt out of any such transfer if the new entity's planned processing of your information differs materially from that set forth in this Privacy Policy.

A third-party payment gateway provider may be required to collect certain financial information from you including, but not restricted to, your credit/debit card number or your bank account details (collectively referred to as “Financial Information”). All Financial Information collected from you by such third party payment gateway providers will be used only for billing and payment processes. The Financial Information collected from you is transacted through secure digital platforms of approved payment gateways which are under encryption, thereby complying with reasonably expected technology standards. The verification of the Financial Information shall be accomplished only by you through a process of authentication in which we shall have no role to play and hence, we shall bear no liability in relation to the same. We shall neither be liable nor responsible for any actions or inactions of third party payment gateway providers or any breach of conditions, representations and warranties given by them. We shall also not be obligated to mediate or resolve any dispute or disagreement between you and such third party payment service providers.

Retention

The Information so collected shall be retained only for the duration necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Once the purposes are achieved, all Information is deleted in a safe and secure mode.

5. CHANGES/AMENDMENT/MODIFICATION TO THE PRIVACY POLICY:

We will treat your Information in accordance with applicable laws, and regulations.

This Privacy Policy is subject to changes and modification based on business, legal or regulatory requirements and will be updated online on the Website. We will make all efforts to communicate any significant changes to this Privacy Policy to you. However, Your continued use of the App after any modification(s) to this Privacy Policy will be deemed as your acceptance to such modification(s). You are encouraged to periodically visit this page to review the Privacy Policy and any changes to it.

6. THIRD PARTY APPLICATIONS, WEBSITES & SERVICES:

Please note that your mobile service provider, mobile operating system provider, third party applications (including the applications pre-loaded on your smart phones powered by Android/iOS platform or customized Android ROM (“Device”), social media platforms and websites that you access may also collect, use and share information about you and your usage. We do not control how these third parties collect, use, and share or secure your Information. For information about third-party privacy practices, please refer or read their respective privacy policies or take appropriate consultation.

The App may include links to other websites/applications or may display advertisements from third parties and other content that links to third party websites. Such websites/applications are governed by their respective privacy policies, which are out of our control. Once you leave our Website, use of any information you provide is governed by the privacy policy of the operator of the website / application you are visiting. That policy may differ from that of the App. If you can't find the privacy policy of any of such websites /application via a link from the website's homepage, you should contact the relevant website /application directly for more information. We are not responsible for the privacy practices or the content such third party websites.

We may use third-party advertising companies to serve ads when you visit the App.

7. NON-PERSONAL INFORMATION:

Non-personal information is defined as any data that does not personally identify you and may include unique system or hardware identifiers, system or application software, and peripherals.

Any non-personal information, when clubbed with personal information shall be treated as personal information.

The following is the manner in which we collect, use, share and retain non-personal information.

Collection

You agree that the App may collect diagnostic, technical, usage related information, for the usage purposes described below, or communicated to you at the time of collection. This information, once collected, is anonymized in a manner that does not personally identify you.

Usage

The above-mentioned information is gathered periodically to provide and improve the App and services therein, facilitate the provision of software updates, product support and other services to you (if any) and to verify compliance with the terms of this Policy.

Sharing

To enable the App partners and third party developers to improve their software, hardware and services designed for use with the App, we may also provide any such partner or third party developer with a subset of diagnostic information that is relevant to that partner’s or developer’s software, hardware and/or services, as long as the diagnostic information is in a form that does not personally identify you.

Retention

The information so collected shall be retained only for a limited duration necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Once the purposes are achieved, all information is deleted in a safe and secure mode.

8. LOCATION SERVICES:

The App, its licensees and agents, may access, collect and analyse your usage of the App and other information related to your location on a regular basis through Bluetooth and Wi-Fi signals and other technologies and data for the performance of the services provided by the App and to help improve the design, functionality, performance, and content of the App. In order to collect geo-location information, the location settings must be enabled on your Device. Therefore, in some cases, the App may request that you enable the location settings.

Except in cases where any specific services requested by you require or involve personal identification, the App collects location data anonymously and in a form that does not personally identify you. By using the App, you agree and consent to transmission, collection, maintenance, processing and use of your location data and queries to provide and improve such services of the App.

9. COOKIES:

Due to the communications standards on the internet, when you visit, access or browse the Website, we automatically receive the uniform resource locator of the site from which site you visit, access or browse the Website, details of the website you visit on leaving SHOPROPAY, the internet protocol (“IP”) address of each User’s computer operating system, type of web browser the User is using, email patterns, and the name of the User’s internet service provider. This information is used solely to analyse overall User trends and to help us improve our Products and services. Please note that the link between the User’s IP address and the User’s personally identifiable information is not shared with third parties without such User’s permission or except when required by law or to provide or facilitate the User with the services. Notwithstanding the above, the User acknowledges that we reserve the right to share some of the aggregate findings, including the information provided by the Users in an unidentifiable, aggregate form, and not the specific data with advertisers, sponsors, investors, strategic partners, and others in order to help grow the business. The amount of information sent to us depends on the settings of the web browser used by the User to access the Website. The User may refer to the browser used, if the User wishes to learn what information is provided to us. "Cookies" are small files placed on your hard drive that assist us in providing our services. We place both permanent and temporary cookies in your Device's hard drive. Information collected by cookies and other technologies are treated as non-personal information. However, to the extent that IP addresses or similar identifiers are considered personal information by local law, we treat any information linked to such identifiers as Information. Similarly, to the extent that non-personal information is combined with Personal Information, we will treat the combined information as Personal Information. Information collected by us, by any means whatsoever, that does not personally identify the User as an individual (such as patterns of utilization described above) is exclusively owned by us and may be used by us and third party service providers for technical administration of the Website, user administration, research, development, and other purposes. You agree and understand that we do not exercise control over third party websites displayed as search results or links on the Website. These other sites may place their own cookies or other files on the Users’ computer or mobile, collect data or solicit Information from the Users, on which we have no control and shall not be held responsible or liable. We do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor do we guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphiQC, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by us of such websites, the websites’ provider, or the information on the website. You understand that you may set or amend your web browsers to delete or disable cookies. If you choose to disable cookies on your computer or mobile telecommunication device, it may impair, degrade or restrict access to certain areas of the Website.

10. OTHER INFORMATION THE APP COLLECTS:

The App also may collect other information about you in ways that the App describe to you or otherwise with your consent. You can choose not to provide us with certain types of information, but doing so may affect your ability to avail and/or use some services or the App.

At the time of installation of the App, the App will require your permission to enable it to find the location of your Device, camera usage, microphone access, SMS, mount and un-mount file systems, etc. You acknowledge that you are agree to providing such information to the App.

11. OPT-OUT:

The third-party service providers with whom we may share Information provided by you are not permitted to market their own services or send promotional e-mails or engage in promotional communication with you. We provide you with the opportunity to opt-out of receiving non-essential, promotional, or marketing-related communication from itself or its partners.

If you wish to remove your contact information from all our mailing lists and newsletters, you can click on the "unsubscribe" link or follow the instructions in each e-mail message. Alternatively, you can contact us at QC@SHOPROPAY.com. We reserve the right to limit membership based on availability of contact information. All Users will be notified by email prior to any actions taken.

12. ACCESS, CORRECTION AND DELETION:

The App strives hard to keep its records updated and accurate with your latest Information. You shall be responsible to ensure that the Information or data you provide from time to time is and shall be correct, current and updated and you have all the rights, permissions and consents to provide such Information or data.

You may note that deletion of certain Information or withdrawal of consent may lead to cancellation of your access to the App or your access to Products, certain features and services of the App. Additionally, we may not be able to process your request of correction, updating or deletion, in case the same is not supported by valid documents or data retention is required by the applicable law or law enforcement requests or under any judicial proceedings or it is extremely difficult to implement (such as requests related to backup copies or if a new system is required to process the request or change of technical design) or risks the privacy of other users.

13. QUERIES AND COMPLAINTS:

We are committed to protect your Information collected and processed by us and look forward to your continued support for the same. In case of any feedback or concern regarding protection of your Information, or any privacy-related feedback or concerns you may contact QC@SHOPROPAY.com