1. https:// ("our", "us", "we", "Website", "",
"'s mobile applications") is committed to the protection of Information provided by
the users ("you", "your", "users") to us. You agree that your use of's services or
our interface implies your consent to the collection and use of your Information in accordance with
the terms of this Privacy Policy ("Privacy Policy").
2. We take the privacy of our users seriously. We are committed to safeguarding the privacy of our
users while providing a personalised and valuable service. In addition to this Privacy Policy, we
have taken the following steps to further safeguard your privacy:
1. General has established a set of "Binding Corporate Rules". These Binding
Corporate Rules are a commitment by to protect your Information
regardless of where the data resides. Depending upon where you live, the Binding
Corporate Rules may provide additional privacy rights through your local privacy
regulator or government. For more information about our Binding Corporate Rules,
including information on how to contact us with any questions, write to us at

Information Collected
1. Traffic Data Collected
We automatically track and collect the following categories of information when you visit our
1. IP addresses;
2. Domain servers;
3. Types of computers accessing the Website;
4. Types of web browsers used to access the Website;
5. Referring source which may have sent you to the Website; and
6. Other information associated with the interaction of your browser and the Website
(collectively "Traffic Data").
2. Information Collected from You
In order for you to access certain areas of the Website, we may require you to provide us with
certain information ("Personal Information"). Personal Information includes the following
1. Your full name, address, e-mail address, telephone number, date of birth and bank or
payment card details and any proof of your identity and/or address that we may request;
2. Details of any transactions you carry out through our Website using your
account and of the fulfilment of your requests;
3. Details of any bank account (including but not limited to, account holder, account name,
account number, sort code, online banking PIN, Transaction Authentication Number
"TAN" and password, available balance and transaction history of your bank account),
ITR, TAX certificates or any other income documents as necessary by us;
4. Details of any credit, debit or other card used by you for transactions;
5. Your participation in any promotion sponsored by us;
6. Correspondence that you send us;
7. Calls that we make to you or you make to us;
8. Surveys that you complete through the Website or based on our request;
9. Information collected through cookies. Please see Paragraph I (Cookies) of this Privacy
Policy for more details;

10. Your IP address, log-in times, operating system and browser type; and
11. Details of your visits to our Website including, but not limited to, Traffic Data, location
data, weblogs and other communication data, whether this is required for our own billing
purposes or otherwise and the resources that you access whilst visiting our Website.
3. In order to fulfil our legal obligations to prevent fraud and money laundering, we will obtain
information about you from third party agencies ("Third Party Information"), including your
financial history, court judgements and bankruptcies, from credit reference and fraud prevention
agencies when you open a account and at any time when we feel it is necessary
to prevent fraud and minimise our financial risks. Please refer to Paragraph 5.2 (Anti-Money
Laundering Policy) of this Privacy Policy for further details.
Personal Information and Third Party Information are collectively referred to as "Information".
Use and Storage of Information
1. We use your Information for the following purposes:
1. To operate and administer your account and to provide services that you
have requested;
2. To carry out your instructions to make and receive payments and undertake transactions
using our services, including verifying that you have sufficient funds in your wallet to make such payments;
3. To allow you to participate in interactive features of the Website;
4. To notify you about changes to our service(s);
5. To improve our internal customer training,
6. To comply with financial services regulations including retention of financial information
and transactions;
7. For financial and identity checks, fraud prevention checks, anti-money laundering and
credit checks;
8. For customer service, including answering questions and responding to feedback and
9. To enhance the security of our services;
10. To ensure that content on our Website is presented in the most effective manner for you
and for your computer; and
11. To provide you with information, products or services that you request from us or which
we feel may interest you.
2. Retention of Data.
We are required under applicable laws to retain certain records for a period of at least 5 (five)
years after closure of your account, which will include your personal data such as
your name, contact details, customer number and transaction history, etc. ("Retained Data").
Other than the Retained Data, we will delete and destroy all Personal Information that we hold
about you when you (or we) terminate your account. We do not store your online
banking login PIN, TAN and/or password.
3. Please note that we will not store your credit card information.
4. Please note that we will never ask you to disclose your personal or security details by e-mail. If
you receive any e-mail purportedly from requesting your personal or security
details, please do not respond to it ("Such E-mail"). Please forward any Such E-mail to
risk@ and thereafter delete the e-mail immediately.
Disclosure of Information
1. We do not disclose your Information to any third parties other than the Website's affiliates and the
1. a prospective buyer of our business or a buyer of a substantial number of the shares in
our business;

2. the police, other lawful enforcement body, regulatory body or court if we are under a duty
or required by law to disclose or share your personal data , or to protect the rights,
property, or safety of ourselves or our group companies, our customers, or others;
3. Financial institutions with whom we partner to jointly provide better services, facilities or
products to you. These financial institutions may only use your information for providing
to you their services and market related products without requiring your
further consent.
4. third parties where you have expressed an interest in receiving information about their
goods and services;
5. third parties who referred you to us initially and to whom we owe a commission payment
as a result of the referral. Where the commission payment is based on transaction
volumes, numbers or types of transactions, we may share that information with that third
party, but we will not disclose the full details of each of your transactions without your
further written consent; and
6. third parties we may occasionally use to provide you with the services that you have
requested. We require these third parties to not use your personal information for any
other purpose.

2. We also use Information in aggregate form (so that no individual user is identified):
1. To build up marketing profiles;
2. To aid strategic development;
3. To audit usage of the Website
3. We reserve the right to disclose Information if required to do so by law or if we believe that it is
necessary to do so to protect and defend the rights, property or personal safety of the Website, or
its users.
Fraud and Credit Agencies.
1. When you open a account, at intervals of up to every 3 (three) months and at any
other time we feel it is necessary to do so to protect our financial interests and prevent money-
laundering or fraud, we share certain information about you and your account,
financial history and transactions as part of our normal business operations with banks, payment
facilitator partners, credit/debit card processing services, identity verification service providers
and credit reference agencies (including, but not limited to) to identify and verify users, to limit our
exposure to fraud and other criminal activities and to manage our financial risk. We can provide
you with a list of the credit reference agencies we use upon your written request
to Helpdesk . When conducting identification or fraud prevention checks, the
relevant parties may retain a record of our query along with your information and may share this
information with other fraud prevention agencies. If you want to know what information these
companies hold about you, you can write to them to request access to your information.
2. Anti-Money Laundering Policy
In order to comply with anti-money laundering laws that exist in various jurisdictions we reserve
the right to report suspicious transactions to federal, state, provincial or local authorities and law
enforcement agencies within those jurisdictions. In exchange for us permitting you to participate
in, use and access our Website and services you hereby grant us the right to report any
transactions which we deem suspicious, as determined solely by acting in its
sole discretion. Examples of a suspicious transaction include but are not limited to use of funds
suspected to be derived from illegal activities, any suspected intention to conceal or disguise
funds derived from illegal activities, or suspicion that the involvement of our Website and services
is in any manner intended to facilitate criminal activity. If for any reason we are of the belief or
become aware of any transaction which we deem suspicious in nature, we may without prior
notice or explanation to you take the following actions, which are in addition to all other rights and
remedies available to us under this Privacy Policy, at law or in equity:
1. report such transaction to the applicable central, state, provincial or local authorities and
law enforcement agencies;
2. de-activate or terminate your account forthwith;

3. withhold any funds held in your wallet; and/or
4. restrict you from registering a account on or with our Website or any of
our affiliated websites.

1. We may contact you via the e-mail address and phone number registered with your account. You may also receive system-generated transactional e-mails such as
confirmations, notification of receipt of payments, notification of password changes etc. which are
necessary for the proper operation and administration of your account. You
expressly consent to receive such communications from us, irrespective of whether your phone
number is registered on the National Do Not Call Registry.
2. As a account holder, you will occasionally receive information by e-mail from us,
unless you have expressly chosen not to receive such communication, about products, services
and special deals which we think will be of interest to you via our newsletter. You can change
whether or not you receive newsletters from us. However please note that you will still receive
communication regarding your account such as transactional e-mails or other
notifications affecting the operation of your account or our legal relationship.
1. Phishing is the name given to attempts to steal personal details and financial account details from
a website user. "Phishers" use fake or "spoof" emails to lead users to counterfeit websites where
the user is tricked into entering their personal details, such as credit card numbers, user names
and passwords.
2. If you receive such an e-mail or are asked for your password by anyone claiming to work for us
please forward the e-mail or report the incident by e-mail to our Data Protection Officer
Links to Our Website and to Other Websites
1. Our Website may, from time to time, contain links to and from the websites of our partner
networks, advertisers and affiliates. If you follow a link to any of these websites, please note that
these websites have their own terms of use and privacy policies and that we do not accept any
responsibility or liability for these policies. Please check these policies before you submit any
personal data to these websites. Please also note that the products and services offered on these
websites may be limited to persons located or residing in only that particular jurisdiction. In
addition, the content on these linked websites may not be intended for persons located or
residing in jurisdictions that restrict the distribution of such content.
2. Our Website also includes social media features, such as the Facebook Like button and widgets,
such as the "Share this" button or interactive mini-programs that run on our site. These features
may collect your IP address, which page you are visiting on our Website, and may set a Cookie to
enable the feature to function properly. Social media features and widgets are either hosted by a
third party or hosted directly on our Website. Your interactions with these features are governed
by the privacy policy of the company providing it.
3. You must always obtain the prior written approval of before creating a hyperlink
in any form from a third party website to any webpage on the Website. may or may not give such approval at its absolute discretion. In normal
circumstances, we may only approve a hyperlink which displays plainly our name or website
address. Any use or display of our logos, trade names and trademarks as a hyperlink will not be
approved unless in very exceptional circumstances and may be subject to a fee as may determine at its absolute discretion. is not responsible for
the setup of any hyperlink from a third party website to any website. Any links so
set up shall not constitute any form of co-operation with, or endorsement by, of
such third party website. Any link to our website shall always be an active and direct link to our
website and shall be made directly to the home or front page of our website only and no "framing"
or "deep-linking" of any webpage of our Website or content is allowed. Please

contact Helpdesk  if you wish to create a hyperlink to any page of our Website on
a third party website.
1. "Cookies" are small computer files that are transferred to your computer's hard drive that contain
information such as user ID, user preferences, lists of pages visited and activities conducted
while browsing the Website. At your option, expense and responsibility, you may block cookies or
delete cookies from your hard drive. However, by disabling cookies, you may not have access to
the entire set of features of the Website.
2. Generally, we use Cookies to customize your experience on our Website and to store your
password so you do not have to re-enter it each time you visit the Website.
3. In addition, our business partners may use Cookies to provide us with anonymous data and
information regarding the use of our Website. Specifically, some of our business partners use
Cookies to show the Website's ads on other websites on the internet as a result of you using the
Website. Such Cookies do not contain any Information. You may opt out of receiving Cookies
placed by such third party vendors by visiting the opt-out page.
4. Other Cookies used by our business partners may collect other non-personally identifying
information, such as the computer's IP address, type of operating system, type of internet
browsing software, what web pages were viewed at what time, the geographic location of your
internet service provider and demographic information, such as gender and age range. This
information is used to provide the Website with more information about our user's demographics
and internet behaviours. You may find out more about the information collected and how to opt-
out of receiving these Cookies by visiting our partner's website.
5. We do not link the information stored in these Cookies directly to any of your Information you
submit while on the Website.
6. In order to comply with legislation, we have reviewed the use of Cookies on our Website and set
out the information below. This is to ensure that you are aware of these cookies and are able to
give your consent for the placing of some or all of these cookies on your device when you use our
Website. In summary, we use the following types of cookies:
1. Strictly Necessary Cookies
These are cookies which are essential for our Website to operate such as those which
identify you so you can log into your account. They allow you to move
around our Website and use the services you have requested. These Cookies will be
activated when you enter our Website and as you use our Website.
2. Compliance Cookies
These include Cookies which are necessary to assist in meeting our regulatory
compliance obligations, such as anti-money laundering and anti-fraud obligations, and
prevent your account from being hijacked. These cookies will be
activated when you enter our Website and as you use our Website.
3. Performance Cookies
These are Cookies that help us to improve how our Website works and to deliver a better
service to you. For example, they will assess which pages you visit most often or if you
get an error message. They also allow us to see if you have used the Website of one of
our group or affiliated companies. All information collected by these Cookies is
aggregated and therefore anonymous.
4. Functionality Cookies
These Cookies allow us to deliver a more personalised service to you and allow our
Website to remember choices you have made such as the language you prefer or the

region you are in. They may also be used to provide services you have requested such
as being able to comment on one of our blogs.
5. Third Party Cookies
When you visit a page on our Website with content embedded from third parties, for
example, YouTube or Twitter, Cookies may be downloaded onto your device. We do not
set or control these Cookies. If you are concerned about the types of Cookies that may
be downloaded you check the third party websites for more information about these
We may use other Cookies from time to time in accordance with this Privacy Policy. By
using our Website and other online services, you acknowledge that we may use some or
all of the Cookies set out in this Privacy Policy and you agree that we can place
performance and functionality Cookies on your device when you use our Website. If you
do not agree to this you should cease using our Website and online services or adjust
your browser settings.
7. Blocking Cookies
Should you want to continue using our services but restrict our use of Cookies, you can block
Cookies by activating the setting on your browser which allows you to refuse the setting of all or
some cookies. However, if you use your browser settings to block all Cookies (including Strictly
Necessary and/or Compliance Cookies, as described above) you may not be able to access all or
parts of our Website. Our Website may issue some of the Cookies described above as soon as
you visit our Website unless you have adjusted your browser setting so that it will refuse Cookies.
Web Beacons
1. In limited circumstances we also may use "Web Beacons" to collect anonymous, non-Information
about your use of our Website and the websites of selected sponsors and advertisers, and your
use of e-mails, special promotions or newsletters we send to you. Web Beacons are tiny graphic
image files imbedded in a web page or email that provide a presence on the web page or e-mail
and send back to its home server information from the user's browser. The information collected
by web beacons allows us to statistically monitor how many people are using the Website and
selected sponsors' and advertisers' websites, or opening our e-mails, and for what purposes.
Website Analytics
1. We may use third party website analytics services in connection with the Website. These website
analytics services do not collect information that you do not voluntarily enter into the Website.
These services do not track your browsing habits across websites which do not use their
services. We are using the information collected from these services to find usability problems to
make the Website easier to use. The recordings will never identify you or your account.
Security Checks, Review and Releases
1. To maintain a high level of security, we reserves the right to conduct a security review at any time
to validate your identity, verify your financial transactions and further document your consent to
this Agreement. To facilitate these security checks, you agree to provide such identification or
other information or documentation as we, in our sole and unfettered discretion, deem necessary.
If you fail to comply with any security request, we reserve the right to void your
account. You will be notified of such verification request by e-mail or telephone and your account balances will be forfeited if you fail to provide us with such requested
documentation and information within the time period reasonably specified by us. Such request
for documentation and information may include a sworn affidavit of identity and eligibility, release
of liability in favour of us and publicity authorization.
User Choice

1. You may choose not to provide us with any Information while accessing the Website. In such an
event, you can still access much of the Website; however you will not be able to access and use
those portions of the Website that require your Information.
Confidentiality and Security
1. Except as otherwise provided in this Privacy Policy, we will keep your Information private and will
not share it with third parties, unless we believe in good faith that disclosure of your Information or
any other information we collect about you is necessary to:
1. comply with a court order or other legal process;
2. Protect the rights, property or safety of or another party.
3. I give consent to to collect KYC documents from PSUs and Government
agencies on my behalf.
4. Enforce our Terms of Use or
5. Respond to claims that any posting or other content violates the rights of third parties.

Public Information
1. Any information that you may reveal in a review posting or other online discussion or forum is
intentionally open to the public and is not in any way private. You should think carefully before
disclosing any personally identifiable information in any public forum. What you have written may
be seen and/or collected by third parties and may be used by others in ways we are unable to
control or predict.
1. We are committed to ensuring that your Information is secure. To prevent unauthorised access or
disclosure of Information we have physical, electronic and managerial procedures in place to
keep your information safe. Once logged into your account, all internet
communication is secured using Transport Layer Security (TLS) technology and the connection is
encrypted and authenticated using AES 128bit encryption key and uses Elliptic Curve Diffie-
hellman key exchange (ECDHE) RSA as a key exchange mechanism.
However, this high level of protection can only be effective if you follow certain security practices
yourself. You must never share your account or login details with anyone. If you
are concerned that any of your login details have been compromised, you can change them any
time once you are logged on but you should always also immediately contact customer services
at Helpdesk  and tell us why you think your login details have been compromised.
Please read our Terms and Conditions for further information on how to keep your account safe.
2. Although we make good faith efforts to store Information in a secure operating environment that is
not open to the public, you should understand that there is no such thing as complete security,
and we do not guarantee that there will be no unintended disclosures of your Information. If we
become aware that your Information has been disclosed in a manner not in accordance with this
Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the
disclosure (to the extent we know that information) as soon as reasonably possible and as
permitted by law.
Updates and Changes to Privacy Policy
1. We reserve the right, at any time, to add to, change, update, or modify this Privacy Policy so
please review it frequently. If we do, then we will notify you here, as well as by posting a notice on
our Website and, where appropriate, a link to the modified policy so that you can review it. In all
cases, use of information we collect is subject to the Privacy Policy in effect at the time such
information is collected.
Your Rights

1. You have a legal right to a copy of any Information about you held by us. You also have a right to
correct any errors in that Information. As mentioned above, you have a right to request that we
cease to use your Information for direct marketing purposes.
Restriction of Liability
1. We makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of
the contents of this Website and expressly disclaim liability for errors and omissions in the
contents of this Website.
2. No warranty of any kind, implied, expressed or statutory, including but not limited to the
warranties of non-infringement of third party rights, title, merchantability, fitness for a particular
purpose and freedom from computer virus, is given with respect to the contents of the Website or
its hyperlinks to other internet resources.
3. Reference in this Website to any specific commercial products, processes, or services, or the use
of any trade, firm or corporation name is for the information and convenience of the public, and
does not constitute endorsement, recommendation, or favouring by us.
4. The contents of this website are under copyright and/or trademark of their original author(s)
unless otherwise noted on the page itself.