Introduction

This document is an electronic record in terms of Information Technology Act, 2000 and rules there under as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

 

This document is published in accordance with the provisions of Rule 3 (1) of the Information Technology (Intermediaries guidelines) Rules, 2011 that require publishing the rules and regulations, privacy policy Wallet terms and conditions for access or usage of Kashware  Wallet issued by RBL through Kashware App/website.We at Kashware respect your privacy and are committed to protecting your personal data. Our Privacy Policy explains how we collect, safeguard and disclose information that results from your use of our Service. The purpose of this privacy policy is to give you a better understanding of: 

 

  1. how we use your information;

  2. how your information is stored and shared;

  3. your rights; and

  4. other useful privacy and security-related matters.

  5. How can you share your concerns regarding privacy with us

 

By downloading/using/accessing the Kashware application as defined for business and/or personal use, you(“User”) indicate that you understand, agree and consent to this privacy policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

 

Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“Agreement”).

We recommend you take the time to read this policy and our Terms and Conditions.

 

This privacy policy is a legally binding contract between You (“User”) and the Kashware (referred here as “We”, “Us”).

We reserve the right, at Our sole discretion, to change, modify, add or remove portions of our Privacy Policy, at any time without any prior written notice to You. The latest & most updated policy can always be found at write the page address

 

While we will make reasonable efforts to keep you posted on any updates to this privacy policy, to make sure that you are aware of any changes, we recommend that you review this policy periodically. 

Your continued use of the Kashware mobile application following the posting of changes will mean that You accept and agree to the revisions. 

Types of Data required and stored as a part of application request to avail our services from us. 

 

Identity

  • Full name 

  • Date of birth

  • Fingerprint

  • ID document details (Passport, Adhaar Card, Driving License and Voter ID)

  • Images of document

  • Selfie photograph

  • Employment status and industry

  • Employment details (e.g. occupation, positions held, employment history, salary and/or benefits) as part of our record retention for Central KYC Records Registry (CKYCR) purposes under Prevention of Money Laundering (Maintenance of Records) Rules, 2005

  • Specimen signature(s) for processing of your instructions received by us through our various payment channels;

  • Opinions provided by you to us by way of feedback or responses to surveys;

  • Calls with our customer services

 

Financial

Details of the funding card(s) added to your Kashware account and your Kashware card including your card number, expiring date, CVV number, name, and billing address

Details of your credit history held at credit reference agencies.

 

Contact

  • Home and shipping address

  • Email address

  • Mobile number

 

Transaction 

 

Information about your transactions and purchases

 

Device

Internet Protocol (IP) address used to connect your computer/mobile device to the internet location, a model of your phone, Geo-location

 

Profile

Your communication preferences, social media handles, feedback, survey, and questionnaire responses.

 

Aggregated

Aggregated Data such as statistical or demographic data. This means your data is bundled up with other people’s data.

 

Tracking Cookies Data

We may use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Examples of Cookies we may use include Session Cookies, Preference Cookies, Security Cookies, & Advertising Cookies.

 

Where do we collect this information from?

Direct interactions, including when you:

  • Create an account

  • Use the product & its features

  • Request marketing

  • Contact us or provide feedback

  • Link accessed by you

 

Automatic collection by us, including:

Technical data from your electronic devices, browsing actions, and patterns. This is collected using cookies, server logs, and similar technologies.

 

From third parties or publicly available information, including: 

  • Analytics providers

  • Payment services and e-wallet providers

  • Customer service providers

  • Electoral register

  • Governmental agencies

  • Credit reference agencies

 

What do we use your information for? 

We’ll only use your data to help provide the best product experience possible and where it's lawful to do so:

Purpose: Signing you up as a Kashware customer and creating your account

Data: Identity, Contact, Financial, Device

Lawful basis: Contract, Legal obligation (the law requires us to verify your identity)

 

Purpose: Confirm your identity and help prevent fraud

Data: Identity, Contact, Financial, Transaction, Device

Lawful basis: Legal obligation, Legitimate interests (to ensure we use the best fraud prevention providers when performing our services)

Purpose: Provide you with Kashware products and services and manage your account

Data: Identity, Contact, Financial, Transaction

Lawful basis: Contract, Legitimate interests (to provide you with services and recover fees)

 

Purpose: Conduct credit checks and provide Kashware credit products and services

Data: Identity, Contact, Financial, Transaction

Lawful basis: Consent

 

Purpose: Process your payment transactions, including Kashware Send

Data: Identity, Contact, Financial, Transaction, Device

Lawful basis: Contract, Legal obligation, Legitimate interests (to facilitate transactions and maintain the integrity of Kashware systems)

 

Purpose: Provide you third-party services, including Samsung Pay

Data: Identity, Financial, Transaction, Profile

Lawful basis: Contract, Consent (for profile data)

 

Purpose: Manage our relationship, including updates to our terms and providing top-notch customer support

Data: Identity, Contact, Transaction, Profile, Device

Lawful basis: Contract, Legal obligation, Legitimate interests (to keep our records updated, delight our customers and improve our product)

 

*Please note we may record your calls with our customer services team for training and monitoring purposes.

 

Purpose: Improve our services and troubleshoot

Data: Identity, Contact, Device

Lawful basis: Legitimate interests (to delight our customers and improve our products)

 

Purpose: Suggest goods, services, programs, or activities that may be of interest to you 

Data: Identity, Contact, Device, Profile, Financial, Transaction

Lawful basis: Consent, Legitimate interests (to develop our product offering and grow our business).

 

Purpose: Send you marketing communications

Data: Identity, Contact, Profile, Device, Transaction

Lawful basis: Consent, Legitimate interests (to ensure you are kept up to date with our services)

 

Purpose: Comply with regulations and legal obligations

Data: Identity, Contact, Financial

Lawful basis: Legal obligation

 

Process with your consent.

In certain jurisdictions, consent is the primary ground on which personal data may be processed by an organisation. In those jurisdictions, processing personal data in connection with the performance of a contract or legitimate purposes is not recognised as an accepted ground on which personal data may be processed.  Accordingly, if you are a resident in such a jurisdiction, you agree that consent will be the ground on which Kashware will process your personal data instead of performance of a contract or legitimate purposes. 

We’ll only ever use your personal data for the purpose we collected it or a similar, connected purpose. If we ever need to use your information for an unrelated purpose, we’ll let you know and explain why. 

Note that we can anonymise or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.

Children

We do not collect and process the personal data of children under the relevant minimum age under applicable local legal requirements except for specific services and upon the consent of the holder of parental responsibility.

Links to Other Websites

We have links to other apps, plugins, or websites that are not owned or controlled by Kashware. We are not responsible for the security or privacy of any information collected by such apps or websites. You should exercise caution and review the privacy statements applicable to the third party websites and services you use. The use of online tracking mechanism by those third party websites and services is subject to those third parties' own privacy policies, and not this Privacy Policy

Kashware may use the collected data for various purposes including but not limited to:

  • To provide and maintain our Service

  • To notify you about changes to our Service

  • To allow you to participate in interactive features of our Service when you choose to do so

  • To provide customer support

  • To gather analysis or valuable information so that we can improve our Service

  • To monitor the usage of our Service

  • To detect, prevent and address technical issues

 

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Kashware will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

Disclosure of Data

When we share data with third parties, they can only process it for specific purposes and in accordance with our instructions. Here’s who we share data with and why:

Kashware group companies 

We share your personal data within our Kashware group of companies in order to provide you with the best service.

Sign-up and verification checks

Identity checking and fraud prevention partners.

When Kashware shares data with identity and fraud prevention partners, they will become a joint controller of your data to determine how your data will be used to best provide their services.

Hosting and IT services

IT vendors including cloud storage providers to securely store your personal data.

Making and sending your Kashware card

Card manufacturing, personalization, and delivery companies.

Payment processing

Financial services providers, including card issuers, payment processors, and banking partners to facilitate payment transactions.

People or companies that you transfer money to from your Kashware card 

Where you make a payment from your Kashware account, we will share your first and last name with the recipient in their transaction history.

You will enter into a separate agreement with AXA to enable them to provide you with insurance. This means AXA is wholly responsible for your data for insurance purposes (rather than Kashware). Further information is available here.

Digital marketing (Google, Bing, Facebook, LinkedIn and others) for targeted marketing purposes

Social media sites, for the purposes of conducting market research and running marketing campaigns. When sharing data with these sites, we ensure that your data is only used in accordance with our instructions.

If you don’t want us to use your information in this way, you can contact us at care@kashware.com or via the app.

Support tools

Analytics and search engine service providers and customer experience support platforms to optimize and improve our services.

If you contact our customer services line out of hours, our external team will manage your inquiries. We will become joint controllers of your data as they will determine the means of collecting your data on our behalf.

Third-party payment partners

Third-party payment service partners including RBL Bank, Zeta, Paytm, Razorpay, HDFC bank, Rupay, Mastercard, and more.

Kashware will only share your data with a third-party payment partner if you have opted to use their service with your Kashware card. When we share your data with third-party payment partners, they will become an independent controller of your data to determine how your data will be used to best provide their services.

Business reorganization/sale

Third parties we may sell the business to or acquire.

We may also share anonymized, aggregated data with selected e-wallet and data analytics service providers. This means your data is bundled up with other people’s data and you aren’t identifiable as an individual. 

 

What are your rights?

Access  the personal data we hold about you and/or in some circumstances, have it sent to another person 

Correct ask us to correct inaccurate data

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

Request deletion of your data, although for legal reasons we might not always be able to do so

Restrict or object to our processing for direct marketing 

Withdraw any consent you’ve given us to use your personal data in a specific way

Request a review of any automated decision made by technology.

You have choices about the personal information you provide Kashware. You may choose not to provide information that we request, but if you do so, we may not be able to provide you a relevant service or a particular feature for an Olam website, app, or product.

If you want to do any of the above, drop our friendly customer support team a line at care@kashware.com or via the Kashware app. We have one month to respond unless your request is complicated, in which case we may need more time. If that’s the case, we’ll let you know. This is almost always free but we’re allowed to charge a reasonable fee or refuse your request if it’s clearly unfounded, repetitive, or excessive.

 

If you fail to provide personal data

 

Where we need you to provide personal data by law, or under the terms of any contract we may have with you, or in order to enter into a contract, we will inform you. If you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a Kashware account). In this case, we may have to cancel a product or service you have with us or provided by other third parties through us, but we will notify you if this is the case at the time.

 

Kashware communication and opting out

You can ask us to stop sending you marketing emails at any time by following the unsubscribe links at the bottom of any Kashware marketing message. You’ll still receive operational emails we need to send you, such as updates to our terms and conditions.

If you would like to stop receiving Kashware receipt emails (for each of your payments), you can change your preferences for each of your funding cards on the Kashware app.

 

Do you make automated decisions about me?

Depending on the Kashware products or services you use, we may make automated decisions about you.

This means that we may use technology that can evaluate relevant factors about you and your circumstances to predict risks or outcomes. We do this for the efficient running of our services and to make sure that the decisions we make are fair, consistent, and based on the correct information.

Where we make an automated decision about you, you have the right to ask that it is manually reviewed by a human. 

For example, we may make automated decisions about you that relate to:

The approval of credit applications: 

  • credit and affordability checks to see whether we can accept your credit application; or

  • setting credit limits.

Opening a Kashware  account

  • anti-money laundering and sanctions checks; and

  • identity and address checks.

Detecting fraud

  • monitoring your account to detect fraud and financial crime.

Our legal basis for our use of automated decision-making is to enable us to fulfill our contract with you or because we have a legal obligation to do so.

How long do we keep your data?

The period for which we may retain data about you will depend on the purposes for which the data was collected, whether you have requested the deletion of the data, and whether we have any legal or regulatory obligation to retain the data. We will not retain data about you for longer than is necessary to fulfill the purposes for which the data was collected. We will typically keep your data for up to 10 years after you last had an active account or product with us, or 7 years after you made or started an application. We may keep your personal data for a longer period where it is necessary for legal, regulatory, or operational purposes.

How can you complain?

We hope you don’t ever need to, but if you do want to complain, you have the right to do so to the Information Commissioner's Office (ICO) however we’d love to try and sort it out first. Drop us an email at care@kashware.com.

How can you contact us? 

If you have any further questions or would like to exercise any of the rights set out above, please contact us at care@kashware.com or via the app. We always welcome your comments or suggestions, including thoughts on how we can improve or clarify this privacy policy.