Privacy Policy
This Privacy Policy explains our policy regarding the collection, use, disclosure and transfer of your information by GeniusNine Info Systems LLP. and/or its subsidiary(ies) and/or affiliate(s) (collectively referred to as the Company), which operates the website (“Site”), mobile applications (App) and other services including but not limited to delivery of spend analytics based on SMS, bill splitting, peer-to-peer money transfer and related content via the site and application, any mobile or internet connected device or otherwise. This Privacy Policy forms part and parcel of the Terms of Use for the App Services. Capitalized terms which have been used here but are undefined shall have the same meaning as attributed to them in the Terms of Use.

As we update, improve and expand the App Service, this policy may change, so please refer back to it periodically. By accessing the website, www.geniusnine.com or otherwise using the App Services, you consent to collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the services that we offer.

The Company respects the privacy of the users of the App Services and is committed to reasonably protect it in all respects. The information about the user as collected by the Company is: (a) information supplied by users and (b) information automatically tracked while using a mobile device having App Services enabled (collectively referred to as Information).

INFORMATION SUPPLIED BY USERS

To avail certain services on the App, users are required to provide certain personally identifiable information for the registration process which may includes:- a) your name, b) email address, c) phone number, d) access to your phone’s SMS inbox, Contact, Call Log, Location, Camera, Storage, Gallery & Other. f) debit card, credit card, bank details and any other such information as required. The Information as supplied by the users enables us to improve the App Services and provide you the most user-friendly experience. In some cases/provision of certain service(s) or utility(ies), we may require your contact address as well.

All required information is service dependent and the Company may use the above said user Information to, maintain, protect, and improve the App Services and for developing new services. We may also use your phone number, email address or other personally identifiable information to send commercial or marketing messages without your consent [with an option to subscribe / unsubscribe (where feasible)]. We may, however, use your email address and phone number without further consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about updates to App Services, billing, etc.).

Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and / or accessible in the public domain. Further, any reviews, comments, messages, blogs posted/uploaded/conveyed/communicated by users on the public sections of the Site or an Application Store (like the App Store or Play Store) becomes published content and is not considered personally identifiable information subject to this Privacy Policy.

In case you choose to decline to submit personally identifiable information on the App/Site, we may not be able to provide certain services on the App/Site to you. We will make reasonable efforts to notify you of the same at the appropriate time. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.

When you register with the App Services, we may contact you from time to time about updation of your personal information to provide the users such features that we believe may benefit / interest you.

INFORMATION AUTOMATICALLY TRACKED WHILE USING THE APP OR SITE

SMS Inbox Information: App also collects partial payment data and other information arising out of transactions made from cards, banks or while using other services through the App user’s SMS inbox, after obtaining the User’s specific consent to allow the App to access the User’s SMS inbox. The App only accesses Business messages that originate from Alphanumeric senders. The App does not access messages that originate from ten digit phone numbers. The collection of such information is only limited to the extent that such data is available in the relevant messages. GeniusNine may also record the identity of the product or service and the price or fee paid or payable in respect thereof.

Demographic and Related Information: We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track the user behaviour on our website. Google Analytics specifically has been enabled to support display advertising to help us gain an understanding of our users’ Demographics and Interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings options provided by Google.

Log File Information: Our Servers automatically collect limited information about your device’s connection to the Internet, including your IP address, when you visit our Site or use the App. We automatically receive and log information from the App and/or your browser including but not limited to IP address, your device or computer’s name, and your operating system, We may also collect log information from your device, including but not limited to your location, IP address, your device’s name, device’s serial number or unique identification number (e.g. Android ID or ADID on your Android Device), your device operating system, browser type and version, CPU speed, and connection speed etc..

Cookies: To improve the responsiveness of the Site for our users, we may use “cookies”, or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (User ID) to understand the user’s individual interests using the identified computer. Our partners may also assign their own cookies to your browser, a process that we do not control.

LINKS TO THIRD PARTY SITES / AD-SERVERS

The Site may include links to other websites. Such sites are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the site you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these sites via a link from the site’s homepage, you should contact the site directly for more information.

INFORMATION SHARING

The Company may share the sensitive personal information with any third party without obtaining the prior consent of the User in the following limited circumstances:
• When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms or for complying with the applicable laws and regulations.
• No personally identifiable data of an individual user such as name, phone number, email address, spends data, card details etc. would be shared with any other User and/or third party – unless explicitly approved by the concerned individual user himself/herself. However, if this conflicts with conditions mentioned in the immediate point above, this condition would become null and void.

The Company may also present information related to user spends, patterns and user data tracked by the company only in the form of aggregated statistics on data such as user spends by category, date, time, bank balances, etc. within our app/site or to our partners.

ACCESSING AND UPDATING PERSONAL INFORMATION

When you use the App Services Site (or any of its sub sites), we make good faith efforts to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

INFORMATION STORAGE AND BACKUP

From time to time, we take backup of your data on our Cloud database. This is done for the purpose of enabling users to get their data back in case their phone’s data becomes unusable, or phone gets lost, or the user moves to a new phone device.

INFORMATION SECURITY

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. 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 App is securely stored within the controlled database. Access to the servers is password-protected and is strictly limited.
UPDATES / CHANGES

We may alter our privacy policy from time to time to incorporate necessary changes in technology, applicable law or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Privacy Policy or the Terms of Use. Any changes we make will be effective immediately on notice, which we may give by posting the new policy on the Site. Your use of the App Services after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform you via electronic mail. In any case, you are advised to review this Privacy Policy periodically on the Site to ensure that you are aware of the latest version.

QUESTIONS / GRIEVANCE REDRESSAL

In the event you have any grievance relating to the processing of information provided by you, you may contact our Grievance Department, at contact@geniusnine.com or write to us at the following address:

GeniusNine Info Systems LLP.,
302, Pushpak Business Hub, Bhumkar Chowk,
Wakad,Pune – 411057,
Maharashtra,
India.