This is the official Privacy Policy (”Policy”) of Trustmore Technologies (P) Limited (“Escrowpay”) which forms a part of your legal agreement with us. The terms “WE”, “OUR” and “US” (refer to “Escrowpay”) and the terms “YOU”, “YOUR” “I” and “USER” (refer to as “User”), as a User of Escrowpay. Please read this Policy carefully to be sure that you understand how we collect and use your information shared with us and under what circumstances we share your information, with any third parties. The information shared by the Users shall be processed in accordance with the terms and conditions agreed under this Privacy Policy and other related policies of the Company such as Terms of Services, Disclaimer etc. as mentioned on www.escrowpayindia.com (hereinafter referred to as the “Website”). Personal information of the Users shall be processed subject to their consent, which shall be deemed when the Users upload/provide their documents for completing the transaction on the Website.

The term “PERSONAL INFORMATION” means any information that you provide to us which personally identifies you to be contacted or identified, such as your name, address, phone number, email address, bank details etc. and any other data that is tied to such information. Our practices and procedures in relation to the collection and use of Personal Information have been set-out below in order to ensure safe usage of the Website for Users.

We have implemented reasonable security practices and measures that are proportional with the information being protected and with the nature of our business. While we try our best to provide security that is best as per the industry standards, because of the inherent vulnerabilities of the internet, we cannot ensure, guarantee or warrant complete security of all information that is being transmitted to us by you.

By visiting the Website, You agree and acknowledge to be bound by this Privacy Policy and hereby consent that we will collect, use, process and share your Personal Information in the manner set out herein below. If you do not agree with these terms, do not use the Website.

1. WHAT TYPE OF INFORMATION DO WE COLLECT AND HOW WE USE IT

We respect the privacy of our Users and are committed to protect it in all respects from any unlawful or illegal disclosure. With a view to offer most enriching and holistic experience of facilitating the use of an escrow account for collection and payment related  transactions to Users, we require certain information which is personal  and varies from individual to individual.

 The information about the User as collected by us shall comprise of:

• information supplied by the Users
• Escrow account opening and Identity related information
• Contact Information
• Usage Based and Technical information
• Financial Information
• information automatically tracked while navigation
• Information of User(s)
• and any third party information supplied to us by the user

2. FOR WHAT PURPOSE THE INFORMATION WILL BE USED
3. To avail the services on our Website, Users are required to provide information related to/for registration and transactions which may comprise of but not limited to names, addresses, email addresses, KYC details, credit / debit card details, bank details etc. The Information, as supplied by the Users, enables us to improve our website and provide youwith the most user-friendly experience.
4. All uploaded and required information is service dependent and the Escrowpay may use the above said User information to, maintain, protect, and improve its services (including advertising services) and shall retain the data uploaded by the Users on the Website for its record keeping purposes.
5. The informationused may comprise of documents for KYC verification which shall include, but not limited to, Credit Bureau records, Aadhar data, PAN data, Bank Statements, Cancelled Cheque,  copies of Agreements or Deeds executed in the past or to be executed in furtherance of the transactions facilitated by us through our Website, chat support messages, emails, contact numbers, SMS, etc.

For General Purpose

1. help us to provide personalized features for our Users;
2. To manage our day to day Business operations
3. To improve our services and business strategies
4. To comply with Laws and adhere to best Compliance and Management Practices
5. For conducting credit and due diligence checks for minimization of risk and frauds
6. For conducting Risk analysis, Anti Money Laundering analysis or any such checks or analysis as prescribed by the regulatory authorities from time to time.
7. to operate, maintain, and improve our websites, products and services – this may include contacting the Users to assist in enforcing our policies, resolving complaints, and ensuring the best possible service according to User’s interest;
8. to get in touch in the case of password retrieval and policy changes;
9. to preserve social history as governed by existing laws or policy.
10. to respond to comments and questions and provide customer service;
11. to send information including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
12. to communicate about promotions, upcoming events, and other news about products and services offered by Escrowpay or its Partners and Vendors.

For Internal Purpose

1. direct our efforts for product and services improvement;
2. contact Users as a survey respondent;
3. any contestrelated information;
4. sending promotional materials from our partners, vendors, sponsors or advertisers.
5. For password reminder and registration confirmation;
6. For regular updates regarding new services, newsletter, special offer and any other related information.
7. changes in any Policies or Terms of Use;
8. event based communications such as order information, renewal notices, invites, reminders etc.

Note: We send Users login details, newsletters and updates upon registration. We also send regular newsletters and/or promotional emails for ourselves or on behalf of our partners, vendors and advertisers directly or through our third party vendors.

Other Usage

We may use User’s information for our legal requirements, which are as follows:

1. to meet any applicable law, regulation or legal process;
2. in response to law enforcement authority or other governmental official request;
3. to enforce applicable Terms of Service, including investigation of potential violations;
4. for detection and prevention offrauds, errors,  security or technical issues;
5. to protect  rightsagainst harmful acts , property or safety of company, our users or the public as required or permitted by law; and
6. for disclosure relating to Merger, Acquisitions, Demerger and other corporate  reconstructing methods , audits or to investigate a complaint or security threat.

Escrowpay hereby explicitly informs the User that any information uploaded, shared or put on the Website by the Users shall be viewable and accessible for the scrutiny, analysis and verification by us or any third party authorized by us to conduct such verifications. We, along with the appointed third party shall be under obligation to keep the information uploaded by the Users on the Website, confidential and private and ensure, to the best of our ability, that there is no unlawful or improper disclosure of the same.

Any information shared by the Users shall be stored in our databases, servers and other record keeping portal for a minimum period of 2 years. The Users shall have the right to request for removal of any information uploaded, stored or entered on Website of the company by making a formal request on email at care@escrowpayindia.com

Note: Such information will not be considered as sensitive, if it is freely available and accessible in the public domain or is furnished under the Right to Information Act, 2005 or any other law for the time being in force.

3. COOKIES

1. We send cookies to your computer in order to uniquely identify your browser and improve the quality of our services. The term “cookies” refers to small pieces of information that a website sends to your computer’s hard drive while you are viewing the site. They help our website remember information about your visit, which can both make it easier to visit the site again and make the site more useful to you.
2. Users may stop or restrict cookies on their computer, laptops or any other electronic system/deviceused for accessing and making use of the Website or purge them from the browser by adjusting web browser preferences and shall consult the operating instructions that apply to the browser for instructions should the Users wish to do so and in general to determine how best to configure the browser setting to meet their requirements. Upon any purge, disabling or turn off pertaining to the cookies, it may be possible that Users may not be able to use all of the features, functions or services available on the Website.
3. We use this information to analyzeand determine Service usage, diagnose service or technical problems, maintain security, personalize content, remember information for efficient access of the account, monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns, and track User content and users as necessary to comply with Information Technology Act 2000, and other applicable laws of India.

4. TRANSFER OF INFORMATION

We do not share your Personal Information with any third party apart from financial institutions such as banks, trustees, payment gateways or other regulatory agencies such as RBI, SEBI, KRA’s etc. or with our service providers and Vendors, which may be necessary to provide You with services that we offer through our Website, conduct quality assurance testing, facilitate creation of accounts, provide technical and customer support, or provide specific services, in accordance with Your instructions. These third parties are required not to use your Personal Information other than to provide the services requested by you.

We may share your Personal Information with our partners, joint ventures, or other companies under a common control (collectively, the “AFFILIATES“) that we may have now or in the future, in which case we will require them to honor this Privacy Policy. We may disclose your Personal Information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our terms and conditions and Privacy Policy; (c) comply with legal process, such as a search warrant, summons, statute, or court order; or (d) protect our rights, reputation, and property, or that of our Users, Partners, Vendors, Affiliates, or the public. Please note that we are not required to question or contest the validity of any search warrant, summons or other similar governmental request or orders that we receive.

We may disclose information in the aggregate to third parties relating to User behavior in connection with actual or prospective business relationship with those third parties, such as advertisers and content distributors.

5. ACTIVITY

We record information relating to your use of our services, such as the searches you undertake, the pages you view, your browser type, IP address, location, requested URL, referring URL, and date and time stamp information. We use this type of information to administer our services and provide the highest possible level of security and service to you.

6. INTELLECTUAL PROPERTY RIGHTS

We own all the intellectual property rights (“IP”) associated with the Website and its content. No right, title or interest in any downloaded material is transferred to you as a result of any such downloading or copying. The Website is protected by copyright as a collective work and/ or compilation (meaning the collection, arrangement, and assembly) of all the content on this Website, pursuant to applicable law.

Our logos, product and service marks and/ or names, trademarks, copyrights and other intellectual property, whether registered or not (“OUR IP”) are exclusively owned by us. Without our prior written permission, you agree not to display and/ or use our IP in any manner. Nothing contained in this Website or the content, should be construed as granting, in any way to the User, any license or right or interest whatsoever, in and/ or to Our IP, without our express written permission.

7. ADVERTISERS, CO-SPONSORS AND LINKS TO OTHERS

The Website may contain or display information from partners, vendors, sponsors, co-sponsors, advertisers, operational service providers, or others that offer information, products and/or services available, and/or that provides opportunities to participate in promotions or engage in activities or that link or redirect User’s browser to other websites, web pages, materials, or organizations.

We encourage the Users to be aware when to leave the Website or take advantage of advertised offers, links or other references, many of which may direct the Users to internet browser, websites or web pages of third parties. Users should read their (third party’s) privacy statements and the terms and conditions that apply as we shall not be responsible for any of the terms and conditions, privacy practices, the content, functions, features, products, activities, and/or transactions you may engage with them when you are using / not using the Website.

If we use operational service providers to serve advertisements when you visit the Website, the operational service provider, in connection with the Website, may use information about your visit to the Website in order to serve the advertisements about products and services that may be of interest to the Users. In the course of serving advertisements on the Website, our operational service providers may use cookies and other technologies.

8. INFORMATION SECURITY

We take appropriate security measures to protect the user’s information against any unauthorized or unlawful access or unauthorized alteration, modification, disclosure or destruction of data uploaded and stored by Users. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

All information gathered on the Website is securely stored within the company’s controlled database. The database is stored on servers well secured behind a firewall; access to these servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee, ensure or warrant  the security of our database, nor can we guarantee that information Users supply will not be intercepted while being transmitted to us over the Internet. Furthermore, any information you post to the discussion areas is available in public domain with accessibility.

The internet is an ever evolving medium. We may change our Privacy Policy from time to time without any notice to incorporate necessary future changes. The changes made will be from immediate effect. Further, to make sure you are aware of any changes, please review this Privacy Policy periodically. Moreover, our use of any information gathered will always be consistent with the policy under which the information was collected, regardless of what the new policy may be.

We use third-party advertising companies to serve ads when Users visit our Website. These companies may use personal information and information about your visits to this and other Websites in order to provide advertisements about goods and services of interest to Users. Any complaints or concerns with regards to content or to report any abuse of laws or breach of these terms and conditions of the Privacy Policy may be taken up with the designated Grievance Officer as mentioned below.

9. GRIEVANCE REDRESSAL

 Any complaints, questions, feedback, abuse or concerns with regards to content and or comment or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email signed with the electronic signature to the Grievance Officer at care@escrowpayindia.com