Privacy Notice - India

1. Privacy Notice

   NIUM India Private Limited and its affiliates’ and subsidiaries (formerly known as
   Instarem India Pvt. Ltd.) (collectively, “Instarem (powered by NIUM)”, “WE”, “OUR”, “US”) respects
   your rights to privacy. Instarem (powered by NIUM) deals with personal information
   collected in accordance with this privacy notice. When used in this notice, “personal
   information” refers to any information, which relates directly directly to our customers and
   users of www.instarem.com or the
   mobile application hereinafter referred to as “SITE”.

    

   Through this Privacy Statement, we want to reassure users that we will not sell, share, or rent user
   information
   to others in a manner different than in this Privacy Statement. By accessing the Site, you agree to be
   bound by this
   Privacy Statement. Each time you use the Site, the current version of this Privacy Statement will apply.

2. What Kinds of Personal Information Do We Collect and Reserve?

   Instarem (powered by NIUM) collects information from users at several different points, including,
   without
   limitation when a user:

   1. registers on the Site;
   2. avail the product or service;
   3. request foreign exchange quotes;
   4. submits an e-mail;
   5. your Government identification document numbers, such as Aadhaar card information, Pancard,
      passport, driving license, proof of identity (POI) and proof of address (POA) details, etc.;
   6. name, address, email address, mobile and home telephone number, age, date of birth, gender,
      citizenship, salary range, occupation and other relevant contact information;
   7. information involving your account information, bank account details including debit, credit and
      transaction history with Instarem (powered by NIUM);
   8. computer and mobile device information, such as the domain and host you use to access the Internet;
      your computer’s IP address; mobile device geolocation, number and other information from and about
      your device (such
      as device properties, settings, applications, stored information and usage) and carrier; the browser
      and operating
      system software you use; websites you have visited or later visit, social profile and network
      information; the date and
      time you access our website, the internet address used to link to our website when you visit us and
      cookie information.

   Instarem (powered by NIUM) monitor traffic patterns on the Site for aggregate use to analyze trends and
   administer the Site to improve its layout, design, and provide unique offers to users. We also monitor
   traffic patterns to
   permit Site personalization and streamlining to create a positive experience for our users, this is
   known as behavioral
   marketing. To perform analysis permitting such personalization and improvement, we may employ third
   parties with
   whom we share the information necessary to accomplish these objectives. These statics include no
   personally
   identifying information.

    

   Where appropriate, we may share aggregated statistical information with our business partners. These
   statistics
   include no personally identifying information.

    

   Except as stated below, we will not share, sell or rent your e-mail address or mobile phone number to
   third
   parties. But, we may do so between our affiliates and subsidiaries. We may, however, share e-mail
   addresses, mobile
   phone numbers and limited personal details with reputable third parties in order to help us provide
   better services.

    

   These third parties agree not use your information for their own marketing purposes.

    

   Instarem (powered by NIUM) is required to collect, reserve and share certain personal information under
   the Anti-Money Laundering and Counter-Terrorism Financing rules and other subordinate instruments
   (AML/CTF Laws).

    

   We may provide personally identifying and/or account information in special case such as enforcement of
   our
   Disclaimers, as required by law or legal process to protect and defend the rights and safety of our Site
   and its users.
   This includes exchanging information with other companies for purposes of fraud and credit risk
   reduction.

    

   By using our Site you agree to the terms and conditions set forth in this Privacy Statement and the site
   Disclaimers INCLUDING ALL LIMITATIONS OF DAMAGES PROVISIONS, which are an integral part of this Privacy
   Statement. By using our Site, You consent to the collection, transfer, storage and use of this
   information by as disclosed
   in this Privacy Statement.

3. Why Do We Collect Your Personal Information?

   We use your information in the following ways:

   1. to carry out our obligations relating to your contracts with us and to provide you with the
      information,
      products and services that you request from us;
   2. to comply with any applicable legal and/or regulatory requirements;
   3. to notify you about changes in our Services;
   4. as part of our efforts to keep our Services safe and secure;
   5. to administer our services and for internal operations, including troubleshooting, data analysis,
      testing,
      research, statistical and survey purposes;
   6. to provide you with information about other similar goods and services we offer;
   7. to provide you, or permit selected third parties to provide you, with information about goods or
      services
      we feel may interest you.
   8. to provide targeted offers, or better ways to use the Instarem service (e.g such as real time alerts
      on
      communication platforms, like WhatsApp, to improve customer experience and benefits).

4. How Do We Collect Personal Information?

   We collect most personal information directly from you by the following means:

   1. through the access and use of the Instarem (powered by NIUM) website or mobile application;
   2. through your registration for our services and/or by setting up an account with us;
   3. through your response to our loyalty program, surveys, contests or claim to a prize announced by us
      from
      any fnancial transaction you make with Instarem (powered by NIUM). All participation in such loyalty
      program,
      surveys, and contests or claim to a prize announced by us are subject to the applicable rules and
      terms and conditions
      of the particular loyalty program, surveys, contests or claim, if any;
   4. through your subscription to our electronic publication such as newsletters, rate broadcast;
   5. from 3rd party connected with you and/or dealing with us.

5. Who Do We Disclose Your Personal Information To, and Why?

   We may share your personal information with other companies in the Instarem (powered by NIUM) Group.
   Sometimes we may disclose your personal information to organizations outside the Instarem (powered by
   NIUM)
   Group such as:

   1. to our contractors or service providers for the purposes of conducting business and providing our
      services
      or products to you, including web hosting providers, IT systems administrators and payment
      processors;
   2. to our intermediary banks in order to process certain transactions on your behalf, for example, by
      disclosing your name and address;
   3. to any of our partners, agents or intermediaries who are a necessary part of the provision of our
      products
      and services;
   4. to international intermediaries to complete your transactions;
   5. to credit reporting bodies, if you are a client of Instarem (powered by NIUM), for the purpose of
      identifying you, in which case the information will be limited to your identity particulars,
      including but not limited to your
      name, gender, address, date of birth and proof of identity document;
   6. to any government regulatory bodies that normally require it or may request it.

6. Security of Information Collected

   To help protect your personal information from unauthorized access and use, we endeavor to use reasonable
   security measures. These measures can include physical, electronic and procedural safeguards such as
   computer
   safeguards and secured files and buildings. We also endeavor to limit access to personal information to
   only employees,
   agents and representatives that need to know. Despite our efforts, third parties may unlawfully
   intercept or access your
   personal information, transmissions to us, or may wrongly instruct you to disclose information to them
   by posing as
   Instarem (powered by NIUM) or by misinforming you about our services. Always use caution and good
   judgment
   when sending money and when using internet and mobile technologies.

    

   Since, no data transmission over the Internet or networks, or method of storage – electronic or otherwise
   can be
   guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot
   guarantee its absolute
   security.

7. Do We Disclose Personal Information Overseas?

   We may disclose your personal information to recipients located outside India. These entities may
   include:

   1. Instarem (powered by NIUM) Group companies;
   2. Instarem (powered by NIUM) Group service providers; and
   3. International Intermediaries.

   To effect, administer and complete transactions or deliver products or services including, but not
   limited to:

   1. companies which help us run or improve the running of our business or which help us deliver products
      and services to you and to banks, card companies, reference agencies, etc.;
   2. in order to comply with legal, regulatory, security and processing requirements, government
      (domestic
      and international) requirements, applicable to us or our affiliates or service providers, including
      but not limited to antimoney laundering laws; and
   3. to organizations which help us process transactions, validate customer information, and prevent
      debt,
      fraud, theft or loss.

   We may disclose Information about current and former customers to perform marketing, business analysis
   and
   advertising services to companies with whom we have contractual or joint marketing arrangements upon
   notice that you
   have provided unambiguous consent (opt-in) for the use of Information for these purposes. In case you do
   not wish to
   receive such communication, you can explicitly write to privacy@instarem.com with Subject “OPT OUT”.

8. Do We Use or Disclose Personal Information For Marketing?

   We will use your personal information to offer you products and services that we believe may interest
   you. We
   will not do this if you tell us not to. Unless you tell us not to, we will disclose your personal
   information to companies
   within the Instarem (powered by NIUM) Group so that they can market their products and services to you.

    

   We also have relationships with advertising companies, who may use cookies, pixels, web beacons, app or
   device information or related information to display advertising tailored to your interests or location.
   To opt-out of tailored
   advertising delivered by other advertising companies, you should choose the appropriate settings in your
   browser(s)
   (e.g., block cookies), device (e.g., turn “Location” of) and app(s). Please note that if you do not
   accept cookies or change
   your device or app settings, you may experience some inconvenience in your use of our website or app and
   some online
   or mobile products and services.

9. Access To and Correction of Personal Information

   You can request access to the personal information we hold about you. You can also ask for corrections to
   be
   made. To do so, please contact us on the details provided under “Contact us”. We retain your personal
   data for the
   period necessary to carry out the purposes outlined in this Privacy Notice, unless a longer period is
   required or permitted
   by law.

10. User’s Right to Deletion

    As per the Instarem policies, deletion may apply where information has been collected from and about the
    customer for the purpose of an Instarem service and where: a customer that has partially registered; has
    an approved
    Instarem account; or has an active NIUM account. The individual can submit a request pertaining to the
    information
    held/collected about them to using the contact details listed below in section 13.

     

    The request will be assessed and handled in line with the InstaReM’s internal Global Data Retention and
    Purging
    Policy which encompasses InstaReM’s obligation to maintaining, keeping, archiving, purging the data in
    accordance to
    the applicable Privacy Laws.

11. Changes In The Privacy Notice and Your Consent

    Instarem (powered by NIUM) reserves the right to modify this Privacy Statement. We urge you to review
    this Privacy Statement when you visit to obtain the most current statement. You have to check
    periodically to view the
    change made in Privacy Notice, we shall not post those changes on our Site to keep you aware of what
    information we
    collect, how we use it and under what circumstances we may disclose it.

12. Resolving Your Privacy Concerns and Complaints

    If you are concerned about how your personal information is being handled or if you would like to make a
    complaint, please contact us on the details provided under ‘Contact us’.

     

    You may request (by contacting us in the manner set out below) details of the information we hold and
    request
    us to correct or erase any erroneous or out-of-date information. We reserve the right to independently
    verify any claims
    made.

     

    To protect your privacy, we shall take reasonable steps to verify your identity before correcting any
    information
    per request. Where permitted by law, we reserve the right to collect a service charge for providing you
    any information
    in connection with your request. All information collected from the first instance with corrections
    shall be kept for 10
    years or as per regulatory requirements. If you explicitly request for deleting all information the same
    can be only after
    10 years or as per regulatory requirements, of your closure.

13. Contact Us

    You can contact us by writing to us at support@instarem.com or post us at Address: NIUM INDIA
    PRIVATE
    LIMITED (FORMERLY KNOWN AS Instarem India Pvt. Ltd.), Attn: Building B3, Level 5 – Nirlon Knowledge
    Park, Off.
    The Western Express Highway, Goregaon (East)

    Our Privacy team can also be contacted in relation to privacy concerns by writing to privacy@instarem.com.
    
    

NIUM India Pvt. Ltd. (formerly known as Instarem India Pvt. Ltd.) is regulated by RBI.