1. OVERVIEW – WHO THIS POLICY APPLIES TO AND WHAT IT IS FOR
At Tigerville Enterprises, we value your privacy and want to be accountable, fair and transparent with you in the way that we handle your personal information. This policy has been designed to provide you with information about how we collect, hold, use, store and disclose personal information about our customers, potential customers, employees, suppliers and others. It also sets out your rights in relation to your personal information that we have and what you can do if you are unhappy with how we handle your personal information.
We are bound by The Information Technology Act (2000), The Information Technology (Amendment) Act 2008 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
By engaging with us in the ways set out in this policy, you confirm that you have read and understood this policy, as it applies to you. All references in this policy to “our website”, refer to the website owned by us at www.efuel.app
2. HOW WE COLLECT PERSONAL INFORMATION
The main way in which we collect personal information is directly from you, including through completion of paper-based or electronic forms, in person or other forms of digital meetings, during phone calls made to or written correspondence with our Support Team, through security video surveillance at our sites or by any other means (including social media, promotions or competitions) through which you engage with us in order to receive information, services or other benefits from us. We also collect personal information through your use of our mobile applications (“the Apps”) and our website.
We may also receive information about you from third parties. This may happen without your direct involvement. For instance, we may collect your personal information from:
- our merchant partners (or their franchisees), including via their participating locations
- our group entities
- publicly available sources of information (such as public registers and social media platforms)
- your representatives (including your legal adviser, executor, or administrator)
- other organisations, who, jointly with us, provide products or services to you
- your employer
- recruitment agencies
- commercial information service providers (such as companies that provide various background checks and fraud prevention reports)
- other third parties (such as those that assist us with marketing activities)
3. COLLECTION AND USE OF YOUR PERSONAL INFORMATION
The purpose for which we use your personal information will depend on the circumstances in which it is collected. Generally, we may use and disclose your personal information:
- a) for the primary purpose for which it is collected;
- b) for a related secondary purpose, where it could be reasonably expected that the information would be used and/or disclosed without your further consent;
- c) for other purposes, where you have authorised us or consented to the relevant use or disclosure; and
- d) as otherwise authorised or required by law.
Where we hold personal information about you that we have collected from different sources, we may combine this personal information into a single record or a collection of linked records. We may also combine or share any information that we collect from you with information collected by any of our related entities (whether within the country where the information was collected or overseas).
The types of personal information we may collect about you and its specific use is dependent upon your relationship with us.
3.1. Visitors to our website
We, or third parties* on our behalf, may collect and use any of the following information about you when you visit our website:
- a) information provided when you correspond with us;
- b) any updates to information provided to us;
- c) if you are a merchant partner (or their franchisee) or their representative, we may also collect the following information (either in respect of you or any individual on whose behalf you are authorised to provide such information): name including title, postal address, email address and phone number;
- d) personal information we collect about you or that we obtain from our third party sources; and
- e) the following information created and recorded automatically when you visit our website:
- (i) Technical information. This includes: your device ID, the Internet Protocol (IP) address of your device; the website address and geographic location (specifically country) from which you access information; files requested; browser type and version; browser plug-in types and versions; operating system; platform etc.; and
- (ii) Information about your visit and your behaviour on our website (for example, the pages and links that you click on). This may include the website you visited before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.
* We may use Google Analytics to help analyse how you use our website. Google Analytics generates statistical and other information about website use (by means of cookies, which are stored on users’ computers). Google will store this information.
3.1.1. How we specifically use your personal information
We will collect, use and store the personal information listed above for the following reasons:
- a) to allow you to access our website;
- b) to receive enquiries from you through the website about our business and services;
- c) to recognise you when you return to our website and personalise your experience, to store information about your preferences, and to allow us to customise your experience on our website according to your individual interests;
- d) to manage our relationship with you;
- e) to administer, improve and maintain our website and to provide technical support for our website;
- f) to measure the efficacy of our systems;
- g) to ensure the security of our website; and
- h) to evaluate your visit to the website and prepare statistical or market research reports to understand trends, usage activities, the kind of people who use our website and their behaviour, how and why they use our website and to make our website more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.
3.1.2. Cookies and other tracking technologies
- c) You may block the cookies we use on our website at any time. To do so, you can activate the setting on your internet browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to optimally use all the functionality provided through our website. You can also delete the cookies already stored on your computer, however, we may not be able to provide you with all the services or functionality you require on our website if you choose to do so.
- d) If you do not want your website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.
- e) We handle personal information collected by cookies (and similar tracking technologies) in the same way that we handle all other personal information as described in this policy.
3.2. Our customers (both consumers and merchant partners (including their franchisees), and including users of our Apps)
- a) Unless you are authorised by another individual to provide their personal information to us, you are only allowed to provide your own personal information when using our services.
- b) We, or third parties on our behalf, may collect, hold and use any of the following information about you (or, in the case of our merchant partners (including their franchisees), if you are authorised to provide information about another individual, that other individual):
- (i) your name;
- (ii) your address;
- (iii) your email;
- (iv) your phone number;
- (v) your date of birth;
- (vi) your gender;
- (vii) your vehicle details (such as make, model, registration number, fuel type etc.);
- (viii) your payment method details (such as bank account details, payment interface details (e.g. UPI ID etc.), or credit, debit or prepaid card details);
- (ix) your transaction records (including date, time and location of each transaction);
- (x) information provided when you correspond with us;
- (xi) any updates to information provided to us;
- (xii) your geographic location data if you are an App user;
- (xiii) your mobile device ID, the Internet Protocol (IP) address used to connect your mobile device to the internet address; the website address and country from which you access information; the files requested; operating system; platform etc. if you are an App user;
- (xiv) information about the products and services we provide to you (including their type, quantity and value):
- (xv) information you provide to help us provide you with improved service for example if we ask you to fill in a survey or questionnaire;
- (xvi) your Credit Agreement information with our merchant partners (or their franchisees) based on data given to us by you;
- (xvii)information about your application for a Credit Agreement with our merchant partners (or their franchisees) including the type and amount;
- (xviii) Credit Agreement balances and limits;
- (xix) default information and when the default has been paid;
- (xx) any new arrangements with our merchant partners (or their franchisees) because of a default
- (xxii) publicly available information; and
- (xxiii) information that we require to identify customers, including as may be required under the relevant Anti-Money Laundering and Counter-Terrorism Financing laws, which may include details or copies of passports or driver’s licences or utility bills or other documentary evidence of identities.
- c) We will only collect sensitive information (e.g. information about your health) where absolutely necessary, and only with your consent or when permissible under applicable laws.
- d) Your phone calls to our Support Team may be monitored and recorded for quality and training purposes.
3.2.1. How we specifically use your personal information
- a) We will collect, use and store the personal information (including Credit Agreement information) listed above for the following reasons:
- (i) to ensure that you are age appropriate to receive our products and services or those provided by third parties (including our merchant partners (or their franchisees);
- (ii) to verify your identity where required (such as for fraud prevention or for the purposes of the relevant Anti-Money Laundering and Counter - Terrorism Financing laws);
- (iii) to personalise and customise your experiences on our website, apps and network;
- (iv) to manage our relationship with you;
- (v) to supply our products and services or those provided by third parties (including our merchant partners (or their franchisees);
- (vi) to register, administer and maintain your account (including to bill you);
- (vii) to deal with any enquiries or issues you have about our services that you request from us, our via our Apps;
- (ix) if you have consented to us doing so for business development and marketing purposes, to contact you (including by phone, SMS or post) with information about our services or the products and services of our suppliers which either you request, or which we feel will be of interest to you;
- (x) to provide you with our services including taking the repayments on your purchases in accordance with the Credit Agreement that you have availed of;
- (xi) for the ongoing management and facilitation of any Credit Agreements you may have with our merchant partners (or their franchisees);
- (xii) to assist you to avoid defaulting on your Credit Agreement;
- (xiv) where we collect your location data, to make you aware of any nearby participating locations and/or provide directions;
- (xv) to support our related business activities;
- (xvi) to carry out statistical analysis and market research (for example, to gain a better understanding of trends, usage activities, your needs and the needs and behaviours of customers generally);
- (xvii)if you are an individual, a sole trader or a non-limited liability partnership and if you have consented, to contact you by email with information about our services or the products and services of our suppliers which either you request, or which we feel will be of interest to you;
- (xviii) to uphold and protect our legitimate interests; and
- (xix) if you are a Merchant, all applicable purposes outlined above, as well as for the following purposes:
- A. to assess whether to enter into a merchant agreement with you;
- B. to enter into and perform our obligations under your merchant agreement with us, and as required by law; and
- C. with your consent, for marketing and research purposes (e.g. to conduct merchant surveys).
- b) Information we need to provide services to you. We need certain types of personal information so that we can provide services to you and perform contractual and other legal obligations that we have towards you. If you do not provide us with such personal information, or if you ask us to delete it, you may no longer be able to access our apps and services.
3.3. Job candidates
We may collect the following personal information about job candidates to facilitate our recruitment processes and pre-employment relationship with them:
- a) contact details, such as name, address phone number and email address;
- b) other personal information included in resumes, such as academic and professional qualifications, employment history and referee details;
- c) licenses, memberships or certifications from professional organisations (such as legal, accounting, engineering) and other similar information that evidences your qualification and/or ability to perform the requirements of the role;
- d) details of identification documents, such as your passport, for the purpose of conducting pre-employment background checks;
- e) photographs and videos;
- f) results of psychometric or aptitude testing and of pre-employment medical, working rights, criminal record and other background checks.
3.4. Employees and individual contractors
In addition to the personal information collected by us in connection with our recruitment activities, other personal information that may be collected by us about our employees and contractors to support a variety of our business and workforce related functions and to comply with applicable laws, includes:
- a) date of birth;
- b) bank account details;
- c) tax identification number;
- d) limited health and medical information;
- e) work performance information;
- f) trade union or other membership details, where requested by you for subscription deduction;
- g) contact details of your nominated emergency contact.
3.5. Suppliers and Vendors
In order to facilitate the acquisition of products and services supporting our business activities and to ensure that our suppliers and vendors are of good character and have the necessary skills and experience, we may collect the following personal information about our suppliers and service providers:
- a) contact details such as name, address, phone number and email address;
- b) financial details (including for payment such as bank account details);
- c) other personal information of owners, directors or employees of the suppliers that may be required to enable us to run necessary background checks or to confirm qualifications. This may include details of identification documents and licences, memberships or certifications.
3.6. Merchant partners (including their franchisees), other operators of participating locations and distributors of our products and services
We collect a range of personal information about directors, shareholders, partners, trustees or principals of the businesses that enter into various types of partnership, distribution or similar arrangements with us to support our commercial activities related to business-to-business and distribution initiatives. This may include the following categories of personal information:
- a) contact details, such as name, address, phone number, email address;
- b) financial details, including bank account details for payment, and details of personal assets and liabilities;
- c) results of background checks that we may need to run, such as:
- (i) good character and criminal background checks, which may include national police checks; anti-money laundering/counter terrorism financing rules global screening checks; and criminal watch list checks;
- (ii) credit file authentication checks;
- (iii) public record checks;
- (iv) bankruptcy records checks (including at an international level);
- (v) land titles checks; and
- (vi) civil litigation checks;
- d) information confirming identity; and
- e) information regarding entitlement to work in the relevant jurisdiction.
Tigerville Enterprises (including its associated bodies corporate) collects personal information about its shareholders, such as:
- a) contact details for share register purposes, including name, address and email address;
- b) shareholding details; and
- c) financial details, including tax identification number and bank account details.
3.8. All others
If you contact our Support Team, we may collect personal information from you to assist you with your query or to process your complaint. While you can contact us anonymously, if you do so, we may not be able to assist you.
Whatever your relationship with us is, we may also collect, use and store your personal information (including Credit Agreement information) for the following additional reasons:
- a) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer service purposes;
- b) to contact you about our products and services (for further information about our direct marketing activities, refer to section 5 below). For example, if you participate in a competition or a contest run by us, we will collect your contact details. We may use those details to market our products and services to you;
- c) to conduct market research and data analytics (including on behalf of our business partners) to better understand your needs, improve our product and services offering, create new product and service offerings and to effectively manage risks;
- d) to detect fraud and to comply with any legal and regulatory obligations;
- e) for internal corporate strategy, compliance, auditing and monitoring, reporting, administration, operational functions, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, quality assurance and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
- f) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
- g) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
3.9. Credit related information
We collect and holds Credit Agreement related personal information about you in connection with you application/s for credit with our merchant partners (or their franchisees), which are predominantly applications for a credit limit for your orders.
In this policy, credit-related personal information includes, but is not limited to:
- a) your Credit Agreement information with our merchant partners (or their franchisees) based on data given to us by you;
- b) information about your application for a Credit Agreement with our merchant partners (or their franchisees) including the type and amount;
- c) Credit Agreement balances and limits;
- d) default information and when the default has been paid;
- e) any new arrangements with our merchant partners (or their franchisees) because of a default; and
- f) other credit-related information that Tigerville Enterprises may collect and hold, such as:
- recruitment or employment related background checks in so far as they contain any credit related information about you; and
- credit information about owners, directors, partners, trustees or similar representatives of our third party suppliers and vendors.
3.10. Sensitive information
Sensitive information is a special category of personal information, such as health information, criminal record information, or information about your trade union memberships, race, religion, sexual orientation or beliefs. As you can see from the above section, we may collect some sensitive information about you in certain circumstances. However, we will only collect such information with your prior consent, unless we are permitted or required by law to do so without your consent.
If you disclose sensitive information to us for any reason, you consent to us collecting the information and using and disclosing it for the purpose for which it was disclosed and as permitted by the relevant laws and regulations.
3.11. Unsolicited personal information
If we receive personal information where we have taken no steps to collect the information, then within a reasonable time we will decide whether we could, under the relevant laws and regulations, have solicited that personal information ourselves.
If we determine that we would not, under the relevant laws and regulation, have been permitted to solicit the personal information, we will as soon as practical (where lawful and reasonable to do so) destroy or de-identify that unsolicited personal information. If we could, under the relevant laws and regulations, have solicited the personal information then we may use and disclose the personal information for the purpose for which it was disclosed and as permitted by the relevant laws and regulations.
3.12. Legal basis for use of your personal information
- a) We consider that the legal bases for using your personal information as set out in this policy are as follows:
- (ii) our use of your personal information is necessary for complying with our legal obligations (for example, identifying you in accordance with the relevant Anti-Money Laundering and Counter-Terrorism Financing laws); or
- (iii) where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
- A. run, grow, develop and refine our business and business practices in accordance with our internal risk appetite;
- B. operate our website and apps;
- C. carry out marketing, market research and business development;
- D. for internal administrative and operational purposes (such as for corporate strategy, compliance, auditing and monitoring, reporting, administration, operational functions, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, quality assurance, to identify and implement business efficiencies etc.);
- F. in order to protect the rights, property, or safety of Tigerville Enterprises or its related entities, our staff, our customers or other persons, which may include exchanging personal information with other organisations for the purposes of fraud protection.
- b) If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of your personal information.
- c) We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described in section 5 below).
- d) If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by notifying us and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to
- a) You must be aged 18 or over to enter into a legally binding agreement with us and purchase products and services from us. Our website and services are not directed at children and we do not knowingly collect any personal information from children.
- b) If you are a child and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete or de-identify that information as soon as reasonably possible.
- c) Please contact us if you are aware that we may have inadvertently collected personal information from a child.
4. DISCLOSURE OF YOUR PERSONAL INFORMATION
Generally, we will only disclose your personal information internally, within our group entities, and/or to third parties:
- a) for the primary purpose for which it is collected;
- b) for a related secondary purpose, where it could be reasonably expected that the information would be used and/or disclosed without your further consent;
- c) for other purposes, where you have authorised us or consented to the relevant use or disclosure; and
- d) as otherwise authorised or required by law (including to comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us).
However, if we sell or buy any business or assets (irrespective of the mechanism i.e. liquidation, takeover, divestment, acquisition etc.), we may disclose your personal information to the prospective seller or buyer of such business or assets and if substantially all of our or any of our affiliates’ assets are acquired by a third party, personal information held by us will be one of the transferred assets.
The third parties that we may disclose your personal information to, vary depending on the particular circumstances in each case, but typically involve service providers that assist us to run our business and fall into the following broad categories:
- a) generally, in a commercial context:
- (i) third party service providers and vendors such as:
- companies that assist with our marketing activities, competitions and promotions, which may include Meta (previously known as Facebook) and Google
- analytics and search engine providers that assist us in the improvement and optimisation of our website and mobile applications, such as Google Analytics
- technology service providers^ that assist us with various technology systems, functions and activities, including ensuring the security of our technology network, mobile applications and payment processing systems
- commercial information service providers and fraud databases (for example those that assist us with fraud mitigation)
- identity verification service providers
- SMS gateways (for example, to send text messages for mobile verification)
- financial institutions such as insurers
- professional advisors
- accountants and auditors
- billing and mailing houses
- logistics providers
- payment facility providers
- (ii) merchant partners (including their franchisees), for activities such as for fulfilling your orders, processing refunds, account reconciliation, settlement etc.
- (iii) loyalty / reward card program operators and partners
- (iv) debt collection, recovery agencies and lawyers; and
- b) generally, in a recruitment and employment context:
- (i) recruitment agencies and associated service providers (such as for pre-employment and ongoing background screening where required)
- (ii) payroll administration services providers
- (iii) pension / superannuation funds or service providers
- (iv) insurers and their agents (for example, to process employee disability / death claims, workers compensation claims etc.)
- (v) medical specialists or allied health professionals (for example, to determine fitness for work and to discharge our work health and safety obligations)
- (vi) other employment related technology service providers.
We may also disclose your personal information to comply with relevant legislative and regulatory requirements or in connection with law enforcement activities, for example, to assist police investigations.
If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should withdraw consent by contacting us and we will stop doing so.
If at any point in time you decide you do not wish to consent to any of the above Google terms, you must uninstall the App immediately. There is no other way to revoke or opt out of the Google Maps functionality and its associated terms, restrictions, and data privacy implications.
4.1. Anonymised and aggregated data
We may also use and disclose anonymised, aggregated reporting and statistics about users of our website, our apps or our services for the purposes of, or in connection with, the supply of products and services to you, internal reporting or reporting to our group or other third parties and for marketing and promotion purposes.
None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
4.2. Transfer of your personal information
- a) Your personal information (including Credit Agreement related information) may be transferred, stored, processed, used or otherwise disclosed overseas by our staff located and operating in countries other than the country where your personal information was collected, or by other members of our group or associated third parties as outlined in this section above. These third parties may not have a link with the country where your personal information was collected and may include entities located in India, Australia, the United Kingdom, the European Union, Russia, UAE, Philippines, Singapore and USA.
- b) The third parties we use may be located in jurisdictions with privacy regimes that are not comparable to that in the country where your personal information was collected. We will take reasonable steps to ensure that any overseas recipient does not use your personal information for any purpose other than as outlined in this policy.
- c) If we provide any personal information about you to members of our group or third parties that are located outside of the country where your personal information was collected, we will take reasonable legal and contractual measures to ensure that the recipient adequately protects your personal information.
- agree with their information handling practices.
- e) By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business.
5. MARKETING COMMUNICATIONS
We may collect and use your personal information from time to time to contact you for marketing e.g. our news, information relating to the Apps, schemes, special offers and other promotional communications, by various means, including post, email, SMS, phone calls, through social media and targeted advertising or by other electronic means (including app-native pop-ups). We may also contact you about products and services offered by our partners. In our marketing activities, we will comply with the applicable privacy legislation, including by obtaining your consent as may be required.
If you use any of our mobile applications, we may also send you direct marketing through in-app push notifications. You can manage these directly in your mobile device settings.
If you wish to modify your preferences or opt-out from receiving marketing communications from Tigerville Enterprises, you can contact us at email@example.com. If direct marketing is by electronic means, such as email or SMS, you can also use the unsubscribe facilities provided in the relevant messages to opt-out. We will not charge you or in any way disadvantage you if you choose to opt out of receiving marketing communications.
If you opt out of receiving marketing communications from us, we will still send you transactional and account maintenance related information and may contact you if we are required to do so by law.
6. YOUR RIGHTS – ACCESS, UPDATE AND OPTING OUT
You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us (see contact details in section 11 below) at any time.
We may request you provide us with information necessary to verify your identity before responding to any request you make. We will consider all such requests and provide our response within a reasonable period and in accordance with applicable laws and regulations.
There may be situations where we may refuse requests, for example if giving access would be unlawful or giving access would have an unreasonable impact on the privacy of other individuals. If we deny you access to the personal information (including credit related information) we hold about you, or refuse to correct your personal information (including credit related information), we will provide you with an explanation for the refusal.
6.1. Access to your information
Subject to any exceptions in the relevant laws and regulations, you have a right of access to any personal information (including credit related information) we hold about you.
If you want to access your personal information held by us, please put your request in writing and clearly identify the personal information you seek access to. This is important to ensure that the information can be retrieved quickly and cost effectively. All requests for access must be addressed to our Privacy Officer (see contact details below).
Depending on the circumstances, we reserve the right to charge you a reasonable administrative fee in connection with your request to access personal information. For example, our reasonable administrative costs might include:
- reasonable staff costs in locating and collating the information;
- reasonable reproduction or photocopying costs; and
- reasonable costs involved in having someone explain the information to you.
If a fee is charged for providing access, you will be advised of the likely cost in advance.
In some instances, we may not release the personal information. For example, if the information reveals the details of a commercially sensitive decision-making process, then we may decide to give you an explanation about the commercially sensitive decision rather than direct access to the information.
6.2. Update or correction of your information
You have a right to request an update or correction to any of your personal information (including credit related information) that we hold.
We are committed to ensuring that your personal information is kept accurate, up to date and complete. We will take reasonable steps to correct personal information that is inaccurate. However, we can only correct or update your personal information if you notify us of any inaccuracies or changes, or if we otherwise become aware that your personal information is no longer accurate. You should contact and notify us if your personal information changes in order for us to keep your information up to date.
If we believe that it is inappropriate to delete or alter the original information, we will discuss with you alternative ways of correcting the information that satisfies the needs of both parties. In this situation, you may also request us to append a statement to your personal information that there is a dispute as to its accuracy.
Where we do not agree to amend credit related personal information held about you, we will provide you with written reasons for our decision and details of how you may make a complaint about our decision.
6.3. Opting out of marketing communications
You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose but may still contact you for transactional or account maintenance purposes.
Please also refer to section 5 above in this policy.
7. PROTECTION OF YOUR PERSONAL INFORMATION
The main risk of our handling of your personal information is if it is lost, stolen or misused. As such, Tigerville Enterprises is committed to protecting your personal information from loss, theft, unauthorised access and disclosure, alteration or any other misuse. We take all reasonable precautions to safeguard the confidentiality and security of your personal information, including through use of appropriate contractual, legal, organisational, physical and technical measures.
The security of your personal information is important to us and we take reasonable steps to ensure that the personal information we hold is secure. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable laws and regulations.
In the unlikely event of a data breach affecting your personal information, we will notify you and/or other relevant authorities, as required by applicable laws and regulations. You should also notify us immediately if you become aware of any breach of security.
Where we have given you (or where you have chosen) a PIN or password, which enables you to access your account with us, you are responsible for keeping this PIN or password confidential. We ask you not to share your PIN or password with anyone.
We store personal information in a range of paper-based and electronic forms.
7.1. Physical security
Where personal information is stored in physical form, we use a variety of mechanisms to protect the security and integrity of such information, which might include:
- locking personal information in cabinets and only giving access to those employees who have a genuine need to use it;
- using other access control measures such as keyed access, security alarms and surveillance cameras to deter and detect unauthorised access.
7.2. Computer and network security
We adopt a number of security measures to protect personal information from unauthorised access via computer systems and networks, which might include:
- access control for authorised users such as user names and passwords;
- limiting access to shared network drives to authorised staff;
- firewalls and port blocking;
- virus and malware scanning;
- specialised IT support to deal with security risks.
7.3. Communications security
In the course of provision of your personal information to us and our ongoing business activities, your personal information may be transferred over the internet or other telecommunications infrastructure, which are not always secure. Although we make every effort to protect the personal information which you provide to us, we cannot provide any assurance regarding the transmission of information over the internet or such telecommunications infrastructure, which usually sits outside our direct control.
As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website or mobile applications and that any such transmission is at your own risk.
Once we have received your personal information, we enhance the security of our transmissions using a variety of mechanisms, which may include:
- Use of PINs, passwords or similar authentication required for some phone and internet transmissions;
- identity checking before disclosing any personal information;
- encryption of data for high-risk transmissions.
7.4. Storage and destruction or de-identification
We will never see nor store the full details of your nominated payment method/s (except your bank account details and payment interface details (e.g. UPI ID etc.)), unless you provide these to us via e-mail or over the phone. Such details are collected, stored and processed by the relevant payment service providers (including payment gateways), who process your payment when you use our Apps.
Personal information in our possession may be retained in archival storage along with our other business-related information (including confidential information). Generally, we will securely destroy or de-identify personal information after a period of seven (7) years following its collection or following an end of your relationship with us unless it is required, or may be required, to be kept for a longer period because of the purpose(s) for which it was originally collected or in line with relevant laws and regulations.
8. LINKS TO OTHER THIRD PARTY WEBSITES OR CONTENT
Our website and mobile applications may contain hyperlinks to websites or content that are not operated by us but by third parties. These hyperlinks are provided for your reference and convenience only and may not remain current or be maintained. They do not imply our endorsement of the activities of such third-party websites or any association with their operators.
We make no representations or warranties in relation to the privacy practices of any third party website or content. We are not responsible or liable for the privacy policies or practices of those linked websites and have no control over them.
9. MAKING A COMPLAINT
If you wish to make a complaint to Tigerville Enterprises about any matters related to our handling of your personal information (including credit related information), such as where you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this policy in respect of your personal information, please provide full details of your complaint to us in writing (see contact details below).
We will need to verify your identity. We take all complaints seriously and will respond to you within a reasonable period of time to both acknowledge (usually within 7 days of receipt of a complaint) and respond to (where practicable, within 30 days of receiving a complaint) your query or complaint. If that is not possible, we will seek to agree a longer period with you. We will notify you of the outcome of our investigation in writing.
10. CHANGES TO THIS POLICY
A copy of the most current version of the policy can also be obtained by contacting the Privacy Officer (see contact details below).
11. CONTACT US
If you have any queries or concerns about our collection, holding, use, disclosure or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, use the following contact details:
The Privacy Officer
Tigerville Enterprises Pvt. Ltd.
This policy was last updated on 9 January 2022.