Privacy Policy

  1. General

1.1.This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents/ records in various statutes as may be amended by the Information Technology Act, 2000 from time to time. This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between the User and Us.

 

1.2. HiWi Forex Transaction Services Private Limited, an Indian company incorporated as per the provisions of the Companies Act, 2013 having registered office at, Enam Sambhav, WeWork, C – 20, G Block Road, Bandra Kurla Complex, Mumbai, Maharashtra- 400051 and its technical processors (“Company”, “We”, “Our” or “Us”) are committed to protecting Your privacy and grant importance to the confidentiality of Your data over internet. This privacy policy applies to all services offered to persons using or visiting (“Users”, “You” or “Your”) Our internet website www.hiwipay.com , Student Portal, EduCon Portal and Remitter Portal (“Website”hereinafter collectively referred to as the “Platform”).

 

1.3.The purpose of this Privacy Policy is to inform the User about the processing of his/her personal data collected when using the services available on the Platform. We collect and utilize Your Personal Information (defined hereinafter) and sensitive Personal Information only to enhance the operation(s) of the Platform, allowing You to use all the listed features and allowing Us to respond to Your requests, if any. The Personal Information is used strictly in line with Our business purposes and to provide You with useful features.

 

1.4.When the User accesses another website through a link or a URL available on the Platform, this Privacy Policy does not apply anymore. We reserve the right to modify at any time this Policy Privacy and to inform User of the same by any mean.

 

1.5.In this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable User, who can be identified, directly or indirectly, in particular by reference to his name, his email address, his IP address (“Personal Information”). Personal Information does not include anonymized information that has been appropriately processed to make it non-identifiable in order to irreversibly prevent its identification.

 

1.6.We respect the privacy of Our Users and are committed to protect it in all respects. The information about the User is collected by Us as (i) information supplied by Users; (ii) information automatically tracked during User’s navigation on the Platform; and/ or (iii) communicated directly to Us via e-mail or telephone or another channel.

 

1.7.User acknowledges that this Privacy Policy, together with terms and conditions, forms Our agreement with the User in relation to his use of the Platform.

 

1.8.For any service that User may use, We only collect the data that is strictly necessary (i) for the delivery of the services, (ii) for the performance of a contract for which User is a party, (iii) for which User has given consent for such processing of data, or (iv) for compliance with a legal obligation to which We are subject.



  1. INFORMATION COLLECTED

2.1.In order to provide services through the Platform, We automatically track and collect the following categories of information when User uses the Platform:

2.1.1.IP addresses;

2.1.2.Domain servers; and

2.1.3.Other information with respect to Users device, interaction of User device with the Platform and applications (“Traffic Data”).

Personal Information collected therefore differs from one User to another, depending on the number of services used by each User.

 

2.2.In order to provide services through the Platform, We may require the User to provide Us with certain information that personally identifies himself. Personal Information includes the following categories of information:

2.2.1.Contact data (such as name, email address, phone number and date of birth); and

2.2.2.Demographic data (such as time zone, postal address and location details); and

2.2.3.If the User communicates with Us by, for example, e-mail or letter, any information provided in such communication may be collected by Us.

2.2.4.Financial data (such as account details, e-wallet details, bank account or credit or debit card details or other payment instrument details etc.) that User may have provided Us.

All such information is stored and/or used for processing orders and under no circumstance are any of these details made available in the public domain. However, We may use this information to share with You additional and/ or upcoming information regarding the services of Platform and to detect and prevent fraud.

2.3.The Platform may transmit User Personal Information to the “Microsoft Azure Blob Storage” cloud servers, to ensure secure storage of data and to other Third Part Service Providers for the purpose of detection and prevention of fraud. Thereby the User is also subject to the terms of Microsoft Azure privacy policy and such Third-Party Service Provider. The Microsoft Azure Blob Storage provides for automated remote backup services that provide for backup and recovery of important data using a secure and trusted server. 

The purpose of backup is to protect the files on the Company systems from catastrophic loss. The backup of files is performed on a 7 (seven) days basis to protect data from being lost due to a hardware or software malfunction. 

 

Further, We have implemented commercially reasonable physical, managerial, operational and technical security measures to protect the loss, misuse and alteration and to preserve the security of the Personally Information in Our care.

You agree and authorise us to use your Contact data , demographic data and Financial data for prevention of fraud, money laundering, risk profiling and to comply with applicable law and we may she these data with third party for the said purposes. 

 

2.4.Our Platform may contain links to third party websites or applications. The User agrees and understands that privacy policies of these websites are not under Our control and the User understands that once he/she leaves Our servers, use of any information provided by the User shall be governed by the privacy policy of the operator of the site used by him.

 

  2.5. Prior to any direct marketing or commercial operation (for example for sending the newsletters or commercial offers), We will first obtain Users consent, either when creating an account on the Website or the App or later by indicating Your choice in account settings. User will always have the right to withdraw his/her consent at any time, directly by clicking on the unsubscribe link available on each email received, by modifying his account settings, or by contacting Us at the following email address helpdesk@hiwipay.com .

 

2.6.In accordance with the legislations in force, User has the right to access, to rectify and to object data concerning himself. Users can access and change the information and preferences provided when an account is created through the account page or by contacting Us.

 

2.7.We may disclose any information We deem necessary, in Our sole discretion, to comply with any applicable law, regulation, legal process or governmental request. Such transfer or disclosure shall be for lawful purposes only. Further, such transfer or disclosure of Your sensitive personal information to other third parties shall only be done once it is ensured that the third party receiving such information saves and process the data as maybe permitted under the law or as per this policy.



  1. SECURITY

3.1.The security of Users Personal Information is important to Us. We follow generally accepted industry standards to protect the Personal Information submitted to Us, both during transmission and once We receive it. All information gathered on Our Platform is securely stored on the “Microsoft Azure Blob Storage” cloud servers. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited.

 

3.2.Although We make best possible efforts to store Personal Information in a secure operating environment that is not open to the public, User must understand that there is no such thing as complete security, and We do not guarantee that there will be no unintended disclosures of Personal Information if such disclosure is not due to the reasons attributable to Us. If We become aware that Users Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, We will use reasonable efforts to notify such User of the nature and extent of such disclosure as soon as reasonably possible and as permitted by law.

 

3.3.Depending on the processing of Personal Information, the data may be subject to a different storage period. Most of the Personal Information is stored for a duration of 2 (two) years from Users last use of the Website, or the App or a service. At the end of the storage period, the Personal Information is purged and therefore deleted from Our database.

 

3.4.We do not sell Users Personal Information to any advertisers or any third party. We use Users Personal Data to display relevant advertisements, based on their preferences. We make reports related to the advertisement campaigns, in particular statistics, without any reference or information related to the personal information of visitors or users of the Platform. User can also block advertising cookies in the dedicated “cookies” page.



  1. DISPOSAL AND DESTRUCTION OF CONFIDENTIAL INFORMATION RECORDS

4.1.Physical or electronic records containing Confidential Information shall be correctly disposed of so that the Confidential Information cannot be retrieved in any manner after destruction.

 

4.2.Most records are not kept permanently unless in the case of accounting records there are local law requirements, which the Company is bound by. Retention periods will be assessed on a case by case basis depending on the business need to hold such information. A ‘Retention Period’ is specified as the minimum period for which a record is retained before it is: transferred for archive or destroyed/ deleted as soon as possible after the minimum required retention period.

 

4.3.The following guidelines shall be used for disposal or destruction:

Paper Media Documents

Shall be shredded or destroyed in such a way that the information contained on the paper media cannot be practically read or reconstructed. Unobanc has a crosscut paper shredder for this purpose.

Electronic Media Documents

Shall be destroyed or erased so that information cannot be practically read or reconstructed. This also includes electronic media stored on laptops or personal computers when they are to be disposed of in any way, using a secure disk erasure application or physically destroying it.

 

4.4.Just removing a file or document in a computer does not mean it is destroyed or deleted since the data in the file is not actually removed from the disk. Applications that provide secure erasure from the disk shall be used to ensure complete deletion/ removal.



  1. CHILDREN PROTECTION

The Platform is not intended for children, and We do not intentionally/knowingly collect Personal Information if You are under the minimum age, as specified under the relevant applicable laws, statutes and/or regulations.



  1. FEEDBACK AND GRIEVANCES

  If You have any questions, comments or concerns about Our privacy practices or would like to provide feedback on the services offered on Platform, please contact Our grievance officer by e-mail at helpdesk@hiwipay.com or telephone at +91 76709 98508 .



  1. ESCALATION MATRIX

HiWi Forex Transaction Services Private Limited tries to make every effort to ensure that the users experience with respect to the services is trouble-free; however there may be times when problems occur. In these situations it may be necessary for the user to use the ‘grievance’ procedure, which provides a fair and logical way of solving problems. It is a quick process and it is in the interest of both parties to resolve the differences amicably and quickly.

The steps involved in resolution of grievances are:

Step 1: User must register the complaint immediately at LEVEL 1. The immediate customer support representative should resolve the issue within 72 (seventy two) working hours from the date of receipt of the grievance.

Step 2: If the grievance is not resolved or the user is not satisfied with the resolution of the grievance, the same may be escalated to LEVEL 2 official i.e. the management of the Company.

Step 3: The immediate supervisor and the management of the Company will study the grievance and hear the user. They will also talk to the persons involved in the process and then communicate the final decision to the user.

Only then will a grievance stand resolved and closed at this last stage. The decision of the management shall be considered as final and binding. The grievance must be addressed by the authority within a pre-defined time frame and communicated to the concerned user.

 

Level 1

Registration of complaint/grievance on:

E-mail: helpdesk@hiwipay.com 

Telephone: +91 76709 98508



Level 2

E-mail: harshit.kochar@hiwipay.com