2. This page informs you about the collection, use and disclosure of personal information we receive from you.
Traffic data Collected:
3. We automatically collect the following information when you visit our website:
(a) IP addresses;
(b) Domain servers;
(c) Types of computers accessing the website;
(d) Types of web browsers used to access the website;
(e) Referring source which may have sent you to the website; and
(f) Other information associated with the interaction of your browser and the website (collectively "Traffic Data").
Information Collected from You
5. 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 information:
a. 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;
b. Details of any transactions you carry out through our website using your Brandtopper account and of the fulfillment of your requests;
c. Details of any bank account (including but not limited to, account holder, account name, account number, sort code, online banking PIN, Permanent Account Number “PAN”, Aadhaar Number, available balance and transaction history of your bank account), ITR, TAX certificates or any other income documents as required by us;
d. Details of any credit, debit or other card used by you for transactions;
e. Your participation in any promotion sponsored by us;
e. Your participation in any promotion sponsored by us;
f. Correspondence that you send us;
g. Calls that we make to you or you make to us;
h. Surveys that you complete through the website or based on our request;
i. Details about your participation in our affiliate programs;
j. Details about the services availed by you from us;
k. Brandtopper points earned by you;
l. Information collected through cookies;
m. Your IP address, log-in times, operating system and browser type;
n. 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.
6. 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, Judgements, Decrees, Orders passed by the Courts or any other Tribunals / forums and bankruptcies, from credit reference and fraud prevention agencies when you open a Brandtopper account and at any time when we feel it is necessary to prevent fraud and minimize our financial risks. Personal Information and Third Party Information are collectively referred to as "Information".
Use and Storage of Information
7. We use your Information for the following purposes:
a. To operate and administer your Brandtopper account and to provide services that you have requested;
b. 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 Brandtopper e-wallet to make such payments;
c. To allow you to participate in interactive features of the website;
d. To notify you about changes to our service(s);
e. To improve our internal customer training,
f. To comply with financial services regulations including retention of financial information and transactions;
g. For financial and identity checks, fraud prevention checks, anti-money laundering and credit checks;
h. For customer service, including answering questions and responding to feedback and complaints;
i. To enhance the security of our services;
j. To ensure that content on our website is presented in the most effective manner for you and for your computer; and
k. To provide you with information, products or services that you request from us or which we feel may interest you.
Retention of Data.
8. We are required under applicable laws to retain certain records for a period of at least 5 (five) years after closure of your Brandtopper 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 Brandtopper account. We do not store your online banking login PIN, PAN and/or password.
9. Please note that we will not store your credit card information.
10. 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 Brandtopper requesting your personal or security details, please do not respond to it ("Such E-mail"). We advise you to delete the e-mail immediately.
Disclosure of Information
11. We do not disclose your Information to any third parties other than the website's affiliates and the following:
a. a prospective buyer of our business or a buyer of a substantial number of the shares in our business;
b. the police, CBI, CVC, other lawful enforcement body, regulatory body, Tribunal 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;
c. 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 Brandtopper related products without requiring your further consent.
d. third parties where you have expressed an interest in receiving information about their goods and services;
e. 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
f. third parties we may occasionally use to provide you with the services that you have requested.
12. We also use Information in aggregate form (so that no individual user is identified):
a. To build up marketing profiles;
b. To aid strategic development;
c. To audit usage of the Website
13. We reserve the right to disclose Information if required to do so by any 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, Company or its users.
Fraud and Credit Agencies.
14. When you open a Brandtopper 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 Brandtopper 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) identify and verify users, limit our exposure to fraud and other criminal activities and manage our financial risk. 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.
Anti-Money Laundering Policy
a. report such transaction to the applicable central, state or local authorities and law enforcement agencies;
b. de-activate or terminate your Brandtopper account forthwith;
c. withhold any funds held in your Brandtopper e-wallet; and/or
d. restrict you from registering a Brandtopper account on or with our Website or any of our affiliated websites.
16. We may contact you via the e-mail address and phone number registered with your Brandtopper 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 Brandtopper 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.
17. As a Brandtopper 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 Brandtopper account such as transactional e-mails or other notifications affecting the operation of your Brandtopper account or our legal relationship.
Links to Our Website and to Other Websites
20. You must always obtain the prior written approval of Brandtopper before creating a hyperlink in any form from a third party website to any webpage on the Brandtopper Website. Brandtopper 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 Brandtopper may determine at its absolute discretion. Brandtopper is not responsible for the setup of any hyperlink from a third party website to any Brandtopper website. Any links so set up shall not constitute any form of co-operation with, or endorsement by, Brandtopper 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.
21. "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.
24. 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.
25. We do not link the information stored in these Cookies directly to any of your information you submit while on the Website.
28. 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.
29. 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
30. 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 Brandtopper account. You will be notified of such verification request by e-mail or telephone and your Brandtopper 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.
31. 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
a. comply with a court order or other legal process;
b. Protect the rights, property or safety of Brandtopper or another party;
c. give consent to Brandtopper to collect KYC documents from PSUs and Government agencies on your behalf;
e. Respond to claims that any posting or other content violates the rights of third parties.
33. 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.
34. You would be wholly liable to any defamatory or inappropriate statements made by you which may be viewed by the general public.
37. 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
38. We make 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.
39. 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.
40. 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.