Website myjar.app and/or the mobile application ‘Jar’ (collectively referred to as the “Platform”) is owned and operated by Changejar Technologies Private Limited, a private limited company having its registered office at No. 752, 18th main, 6th block, 5th cross Koramangala Bangalore-560095, which shall include its affiliates and group entities, together referred to as “Company”, “We”, “Us” or “Our”.
We respect your privacy and hence handle your personal data with the utmost care and confidentiality.
Digital Gold Services
This privacy notice supplements the other notices/policy and is not intended to supersede them.
- COLLECTION OF INFORMATION
To provide you the services, we collect, use and process your personal information including your sensitive information. The types of personal information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with the Company and the requirements of applicable law.
- Information that You Provide to Us:
- While registering on Our Platform for using Our Services, We collect Your Personal Information including sensitive personal information such as name, mobile number, email address, password, date of birth, gender. We use your contact information, such as your email address or phone number, to authenticate your account and keep it, to secure our services and to help prevent spam, fraud, and abuse. We also use contact information to personalize our Services, enable certain account features and to send you information about our Services. If you provide us with your phone number and email id, you agree to receive text messages from Changejar/ Jar to that number. In addition to the Personal Information mentioned above and in order to provide Services to You when you purchase Gold in excess of 30grams We may also collect your KYC information including Your Proof of identity like Aadhaar number , driving license, PAN number, finger – print details and signature solely for completing the account opening procedures and authenticating Your transactions on the Platform. The act of providing Your Aadhaar is voluntary in nature and the Company, hereby agrees and acknowledges that they will collect, use and store such details in compliance with applicable laws and this Privacy.
- You may also be asked for certain financial information, including Your billing address, bank account details, credit card number, expiration date and/or other payment related details or other payment method data, and debit instructions or other standing instructions to process payments for the Services. All the payment transactions made through the Platform are electronically processed by third party service provider. All UPI payments and/or card payments are subject to authorisation by UPI service providers and/or card issuer and are electronically processed by UPI payment aggregators or approved payment gateway providers.
- If You choose to post messages on our message boards, chat rooms or other message areas or leave feedback, We will collect and store such information You provide to Us. We retain this information as necessary to resolve disputes, provide customer support, respond to queries and inquires, and troubleshoot problems and improve the Services.
- We may ask You to provide certain additional information about Yourself on a case-to-case basis. All information disclosed by You shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/misrepresentation/ fraud/negligence, etc. of the information disclosed shall lie on the Company nor will the Company be in any way responsible to verify any information obtained from You.
- You have every right to edit, modify, review or delete any information including sensitive personal information provided to us.
- Automated Collected Information
In addition to the information that you provide us directly, we also collect information that You provide to Safe Gold and other third parties for providing Services and for technology support like application programming interfaces (APIs) and embeds to make that information available in our database. 2. We may retrieve from Your records available with third party including from Know Your Customer (KYC) Registration Agency (KRA) such as name, KYC details, KYC status, father’s name, occupation, address details and related documents.;
- Usage and Log Information: To make our Platform and Services more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP)address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time of your visit. We use this information to examine our traffic and to view how our customers use our website. This type of information will not allow you to be personally identified although we might be able to associate it with your account. We process this usage data to facilitate your access to our services in technical terms (e.g. to adjust our services to the terminal device you are using), and to recognize and stop any misuse. We also use usage data in anonymised form for statistical purposes and to improve our website . Further, if You choose to invest through the Platform, We will also collect information about Your transactions including transaction status and details and Your investment behaviour. We process this data to provide you Services.
- Location Information: When and if You download and/or use the Platform through Your mobile, We may receive information about Your location, Your IP address, and/or Your mobile device, including a unique identifier number for Your device. We may use this information to provide You with location-based Services including but not limited to search results and other personalized content. You can withdraw Your consent at any time by disabling the location-tracking functions on Your mobile. However, this may affect Your enjoyment of certain functionalities on Our Platform.
- Third party information: We also collect information from third parties on the tracking technologies to track the activity on our service and hold certain information. Browser based, network based, AD- Tracking, User UX behaviour tracking information is collected from third parties. We collect information to understand and track the behavioural as means for security and connection integrity. We will keep such information for our reference and will never share with any third party.
Also, please remember that the manner in which third party services collect, use, store and disclose Your information is governed by the policies of such third parties, and Platform and/or Company shall have no liability or responsibility for the privacy practices or other actions of any third-party services that may be enabled within the Service.
iv) Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Services or on Third Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on ourPlatform, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
The information collected allows Us to provide the Services and features on the Platform that most likely meet Your needs, and to customize the Platform to make Your experience safer and easier.
However, You can browse the Platform without telling Us who You are or revealing any Personal Information about Yourself. In such a case, we will only collect and store the Non – Personal Information. Once You give us your Personal Information, You are not anonymous to Us. Wherever possible, while providing the information to Us, We indicate which fields are mandatory and which fields are optional for You. You always have the option to not provide the Personal Information to Us through the Platform by choosing to not use a particular Service or feature being provided by Us on the Platform, which requires You to provide such information. We may automatically track certain information about You based upon Your behaviour on the Platform. We use this information to do internal research on Your demographics, interests, and behaviour to better understand, protect and serve You. This information is compiled and analysed by the Company on an aggregated basis and not individually, in a manner that does not specifically identify You.
- USE OF YOUR INFORMATION
We use the Personal Information and other non-Personal Information, for the following:
- to provide and improve the Services on the Platform that You request;
- to resolve disputes and troubleshoot problems;
- to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users;
- collect money from You in relation to the Services,
- inform You about online and offline offers, products, services, and updates;
- customize Your experience on the Platform or share marketing material with You;
- to detect, prevent and protect Us from any errors, fraud and other criminal or prohibited activity on the Platform;
- enforce and inform about our terms and conditions;
- to process and fulfil Your request for Services or respond to Your comments, and queries on the Platform;
- to contact You;
- to allow Our business partners and/or associates to present customised messages to You;
- to communicate important notices or changes in the Services provided by the Company, use of the Platform and the terms/policies which govern the relationship between You and the Company and with Our affiliates as set out in paragraph 3 below for providing services to You; and
- for any other purpose after obtaining Your consent at the time of collection.
Further to the above, You may also choose to provide Your explicit consent to connect/integrate Your email account(s) and/or registered mobile number with Your account on the Platform by clicking on the authentication email/message sent by the Company on Your registered email address and/or registered mobile number. You will be expressly asked in each case whether You want to connect Your email address and/or Your registered mobile number with Your account on the Platform. You can also choose to enable Our access to one or more of Your email accounts by connecting such account(s) with Your account on the Platform. Once connected, the Platform will securely access and analyze the emails and passwords and in case of registered mobile number, Your text messages, if any to populate and track Your investments details and history including those made through the account on the Platform and consolidate them at one place. Such data obtained by this integration will be used by the Company solely for providing the Services and improving Your experience of the features of the Platform and to consolidate your investment details and history. The Company hereby agrees and acknowledges that it shall not use or transfer any data or information received from the integration of the email addresses with the account on the Platform to third parties for serving ads, including retargeting, personalized, or interest-based advertising. However, we may share the same with Safe Gold and its affiliates for providing you the Services.
You also specifically agree and consent to Us for collecting, storing, processing, transferring and sharing information (including Personal Information) related to You with third parties solely for the purpose of processing your transaction requests for the Services. Unless and until, You explicitly give Your consent to Us, to do so, We will not share Your Personal Information with another user of the Platform and vice versa.
- SHARING OF INFORMATION
We may also disclose Your Personal Information to third party vendors, consultants, and other service providers who work for the Company, who are bound by contractual obligations to keep such personal information confidential and use it only for the purposes for which We disclose it to them. This disclosure may be required for Us, for instance, to provide You access to Our Services and process payments including validation of Your bank accounts, to facilitate and assist Our marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to Our Services.
You also specifically agree and consent to Us for transferring and sharing your sensitive personal information (including your biometric data, financial information, passwords) related to You with Our partners, collaborators including Safe Gold and its affiliates, third parties and other service providers solely for the legitimate purpose of proving you the Services.
We do not disclose Your Personal Information to third parties for their marketing and advertising purposes without Your explicit consent.
The Company may disclose Your information, to the extent necessary:
- to comply with laws and to respond to lawful requests and legal process,
- to protect the rights and property of the Company, Our users, and others, including to enforce the Terms, and
- in an emergency to protect the personal safety and assets of the Company, the users, or any person. In such an event the Company is in no manner responsible for informing You or seeking Your approval or consent.
- LINKS TO OTHER THIRD-PARTY SITES AND COLLECTION OF INFORMATION
- SECURITY PRECAUTIONS AND MEASURES
Our Platform has reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration of the information in compliance with applicable laws. Further, whenever You change or access Your account on the Platform or any information relating to it, We offer the use of a secure server. We cannot however ensure or warrant the security of any information You transmit to the Company or guarantee that Your Personal Information and/or other Non-Personal Information provided for availing the Services or Platform may not be accessed, disclosed, altered or destroyed by a breach of any of Our security measures and safeguards.
It is further clarified that You have and so long as You access and/or use the Platform (directly or indirectly) the obligation to ensure that You shall at all times, take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information. When payment information is being transmitted on or through the Platform, it will be protected by encryption technology. You expressly consent to the sharing of Your information with third party service providers, including payment gateways, to process payments and manage your payment-related information. Hence, the Company cannot guarantee that transmissions of Your payment-related information or Personal Information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by the Company or the Company’s third-party service providers. The Company assumes no liability or responsibility for disclosure of Your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control. You play an important role in keeping Your personal information secure. You shall not share Your Personal Information or other security information for Your account with anyone. The Company has undertaken reasonable measures to protect Your rights of privacy with respect to Your usage of the Platform controlled by Us and Our Services. However, We shall not be liable for any unauthorized or unlawful disclosures of Your personal information made by any third parties who are not subject to Our control.
- DATA STORAGE AND RETENTIONPOLICY
We collect and store your data and Personal Information in AWS cloud as you use services and will retain the data for as long as necessary to fulfil the purposes for which it was obtained. Processed and non-identifiable data, however, will be perpetually stored.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8.YOUR PRIVACY RIGHTS
10. GRIEVANCE OFFICER
If You have any privacy concerns, please feel free to reach out to the grievance officer, the name and contact details of this Officer have been provided below:
Name: Mr. Pankaj Parihar
He shall try to acknowledge the complaint within twenty-four hours and dispose of such complaint within a period of fifteen days from the date of receipt of complaint.
Effective as on 22nd April 2022
Registered Office address: No 752, 18th main,6th block,5th cross Koramangala Bangalore -560095.
1. INFORMATION WE COLLECT
1.1 Sensitive Data and Personal Information: In general, We may collect Personal Information, including Sensitive Data.
“Personal Information” means individually identifiable information that directly or indirectly, in combination with other information would allow the identification of a specific living person.
“Sensitive Data” means Your Personal Information such as financial information such as bank account details and/ or any other payment instrument details, sexual orientation, any details that may have been voluntarily provided by You and any of the information received under above clauses by Us in connection with availing the Services.
By providing Personal Information (including Sensitive Data) to us, you consent to the collection, usage, and disclosure of Personal Information (including Sensitive Data), as permitted by applicable laws. By using the Services, you are authorizing us to gather, parse data and retain basic data which are related to the provision of the Services.
1.2 Personal Information: We may collect and process your Personal Information, including but not limited to the following:
1.2.1 Information provided by you at the time of registration such as your name, address, email ID, phone number, bank account details, financial information, unique identifiers, and preferences information including favourites and history;
1.2.2 Information that you provide to us directly via email and/ or electronic communication;
1.2.3 Your bank account statement provided by you through the upload feature during the onboarding process on Jar Platform to assess your creditworthiness;
1.2.4 Your live selfie for your identity check and verification with your KYC documents. The image captured through this selfie may be shared with third party for the purpose mentioned in Clause 3.3 herein;
1.2.5 Information that you provide to us over telephone. We may make and keep a record of such information shared by you;
1.2.6 Information that you provide to us in physical form whether sent through post and / or courier and / or handed over to our representatives in person;
1.2.7 Any other additional information required to be provided via email/ electronic communication/ telephone/ post/ courier after your registration; and
1.2.8 Hardware model, operating system and versions and identifiers like IMEI number and serial number of your primary device used for availing Services.
1.2.9 Information from other sources.
1.3 Domain Name and IP Address: We may collect your domain name which is linked to every computer/ mobile device connected to the internet and a set of numbers that serve as that computer’s Internet Protocol or “IP” address. When you request a page from any page within the Website, our web servers automatically recognize your domain name and IP address. The domain name and IP address does not reveal any further information about you other than the IP address from which you have accessed the Website.
1.4 Cookies: If enabled, we may place cookies on your machine that store small amounts of data on your computer about your visit to any of the pages of this website. Cookies can identify the pages that are being viewed and this can assist us in tracking which of our features appeal the most to you and what content you may have viewed on past visits.
1.5 SMS: We do not collect, read, store or share with third parties your personal SMS, other than the SMS pertaining to your financial transactions solely to assist our lending partners in assessing your credit risk.
1.6 Phone: We shall take one-time access of certain features of your mobile phone to facilitate on-boarding on the platform and KYC verification:
- IP Address
1.7 Biometric Data: No Personal Information of yours containing biometric data will be collected or stored by Jar unless permitted by extant statutory guidelines.
2. HOW WE USE INFORMATION WE COLLECT
Our primary goal in collecting the information is to provide you a platform to render our Services. We may use the personal information provided by you for one or more of the following:
a. To help provide you the Services;
b. To observe, improve and administer the quality of Services;
c. To analyze how the platform is used and diagnose technical problems;
d. Remember the basic information provided by you for effective access;
e. To confirm your identity in order to determine your eligibility to use the platform and avail the Services
f. To notify you about any changes to the Website;
g. To enable us to comply with our legal and regulatory obligations;
h. For the purpose of sending administrative notices, Service-related alerts and other similar communication with a view to optimizing the efficiency of the Website;
i. Doing market research, troubleshooting, protection against error, project planning, fraud and other criminal activity; and
3. DISCLOSURE OF INFORMATION
3.1 We do not publish your Sensitive Data provided by you.
3.2 We will treat your Personal Information strictly confidential. We will not disclose your Personal Information to anyone, except in the following cases:
- We may disclose your Personal Information in the event it is required to do so by law, rule, regulation, law, enforcement, governmental official, legal or regulatory authorities and/ or to such other statutory bodies who have appropriate authorisation to access the same for any specific legal purposes.
- Merger, acquisitions: Information collected from you may be transferred to a third party(ies) as a result of a sale or acquisition, merger or bankruptcy involving the Company.
- We may disclose your information to any of our affiliates or related entities. We will ensure that our affiliates and related entities maintain the same standards of confidentiality and protection with respect to the Personal Information shared with them.
- We may disclose your information in order to provide you the Services, enforce or apply the Terms and Conditions of Use, or to protect the rights, property or safety of the Company, its users or others. This includes providing information to one or more lending partners, and exchanging information with other companies / agencies that work for fraud prevention.
3.4. Consulting: We may partner with other parties to provide specific portions of the Services, if required. When you sign-up for the Services, we may share some of your Personal Information (including phone number registered or to be registered with Jar) and Sensitive data to the extent necessary for the third party to provide these Services. Our contractual arrangements with such third parties restrict these parties from using personally identifiable information except for the explicit purpose of assisting in the provision of these Services.
3.5. Promotional Offers: We may send you offers, which may be on behalf of other businesses. If you do not want to receive such offers, you may request us to adjust your preferences.
4. CHANGE OF INFORMATION
If your Personal Information or Sensitive Data changes, you may correct, delete inaccuracies, or amend information by reaching out to us at ID: firstname.lastname@example.org. We may request you to provide any additional information or documents as may be necessary to verify the changes requested by you.
5. SECURITY OF INFORMATION
5.1 We take the security of your information very seriously. To this end, we use several security techniques including secure servers at India, firewalls, and encryptions, as well as physical safeguard of the locations where the data are stored. We have in place appropriate administrative, technical, physical safeguards and security measures to protect the personal data you provide to us against accidental, unauthorized, or unlawful loss, destruction, damage, alteration, access, disclosure or use and any other unlawful forms of processing. When we collect data, we collect your personal details on a secure server. We use firewalls on our servers. Whilst we are unable to guarantee 100% security, this makes it hard for a hacker to decrypt your details. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage and disclosure of your information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you. You are responsible for protecting against unauthorized access to your password and to your computer.
5.3 In using the Services, you accept the inherent security implications of data transmission over the internet. Therefore, the use of the Website will be at your own risk, and we assume no liability for any disclosure of information due to errors in transmission, unauthorised third party access or other acts of third parties, or acts or omissions beyond its reasonable control and you agree not to hold us responsible for any breach of security.
5.4 In the event we become aware of any breach of the security of your information, we will promptly notify you and take appropriate action to the best of its ability to remedy such a breach.
6. DATA RETENTION
You may request us to delete your information or revoke the consent to access or opt out of processing your application by submitting a request for account deletion through the Jar mobile app via the profile section. On submitting a request to delete Your account, you confirm/understand that:
1. You have no outstanding credit facility availed on the Jar platform.
2. You have no pending or potential grievances in relation to any of your previous dealings with Us.
3. Your account will be permanently deleted. We will not be able to reactivate your account.
4. You will receive no further communications from Jar.
You however understand that We will be required to or retain, and accordingly use and disclose any specific data if required by law, rule, regulation, law, enforcement, governmental official, legal, or regulatory authorities and / or to such other statutory bodies who have appropriate authorisation or for the purposes of completing any legal obligations or for audit requirements. We will not retain your Personal Information(including sensitive personal data) for longer than is required for the purpose for which the information may lawfully be used.
7. NOTIFICATION OF CHANGES
Using the Company’s Services or accessing the Website after a notice of changes has been sent to you or published on the Website will constitute your consent to the changed terms.
It is very important that any Personal Information we hold/pass on to our lending partners about you is up to date and correct. Please inform us at email@example.com for any changes to your Personal Information.
8. ADDRESS FOR PRIVACY RELATED QUESTIONS
To offer optimum support to our customers and to address complaints and grievances in the most effective manner, we have set out the process for registering and getting the complaint addressed.
In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below.
Name: Mr. Pankaj Parihar
Address: No.752 Vasantham Building, 18th main, 6th block, 5th cross Koramangala Bangalore - 560095
Email ID: firstname.lastname@example.org