Privacy Policy

Scapia Technology Private Limited (“Scapia”, “the Company” "We", "Us", or "Our"), a private limited company with its registered office at 2nd floor, Tower B, Mantri Commercio, Kariyammana Agrahara, Bellandur, Bengaluru, Karnataka 560103, India which operates and manages the Web based platform www.scapia.cards (the “Platform”) is committed to protecting Your privacy and the information that You share while Using the Platform. We value the trust You place in Us.

That’s why, We maintain the highest security standards for securing the transactions and Your information.

This privacy policy (“Privacy Policy”) specifies the manner in which personal data and other information is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company. This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party through the Platform, and any Third-Party Sites that You access or use in connection with the Platform Services.

Please read the Privacy Policy carefully prior to using or registering on the Platform or accessing any material, information or availing any Platform Services through the Platform.

By clicking the “I accept” button provided at the sign-up page for the Platform, You (“You”, “Your” as applicable) accept and agree to be bound by the terms and conditions of this Privacy Policy and You hereby consent to Us collecting, processing, using, disclosing, sharing and transferring Your Personal Information (defined below) and other information (recorded below) in the manner stated in this Policy. This Privacy Policy is incorporated into and subject to Our terms of use (“Terms”) and shall be read harmoniously and in conjunction with the Terms. All capitalized terms used and not defined in this Privacy Policy shall have the meaning ascribed to them under the Terms.

This Privacy Policy (i) is an electronic record under the Information Technology Act, 2000 read with rules and regulations made thereunder and is generated by a computer system; and (ii) will not require any physical, electronic, or digital signature.

1. Collection of Information:

We collect Personal Information (defined below) when You register or set up an Account on the Platform. You may browse certain sections of the Platform without being registered with Us. However, to avail the Platform Services on the Platform, You are required to set up an Account with Us.

This Privacy Policy applies to the following information :

1. Information You give Us: You may provide certain information to Us voluntarily while registering on Our Platform for availing Platform Services, such as name, mobile number, Your email address, gender, date of birth, nationality, Your username, Your residential address, etc. along with such other information in the course of You registering or setting up an Account on the Platform. In addition to the above Personal Information, We may also collect Your permanent account number, Your bank statement, Your Aadhaar, Your live selfie photo and request one-time access to Your location data at the time of sign up on the Platform for verification purposes. The information collected in the course of You signing-up on the Platform shall solely be used for completing the Account opening procedures and authenticating Your transactions on the Platform.The above information is collectively referred to as (“Personal Information”).

2. Non-Personal Information: We may also collect non – personal information such as Your internet protocol address, geographic location (through a one-time permission to access such information), operating system, referral source, browser type and version, length of visit, page views, website navigation etc. which will not identify with You specifically (“Non – Personal Information”), while You browse, access, or use the Platform. We may analyze Our web – page flow, track User trends, measure promotional effectiveness, and promote trust and safety based on the Non-Personal Information that We collect. We may also offer certain additional features on the Platform that are only available through the use of a “cookie”. We may place both permanent and temporary cookies in Your computer/mobile device’s storage drive to collect information such as Your device ID, make and model of Your device, operating system of Your device, etc. for the purpose of facilitating app functionality, user communication and analytics.

3. Transactional Information: When You choose to avail Platform Services, or when You make any payments to Us or when You receive any payments from Us for any reason whatsoever, We may collect Your bank account details and the details of the transaction undertaken by You on the Platform (“Transactional Information”). We may track Your transactional activities on the Platform including but not limited to Your use of Scapia Coins etc. on the Platform. All Transactional Information gathered by Us shall be stored on servers, log files and any other storage system owned by Us or by third parties in India, and such storage will be need-based and to the extent required to render Platform Services. Our primary goal in doing so is to provide You a safe, efficient, smooth, and customized experience on the Platform. Notwithstanding the foregoing, if You are a user of the Scapia Federal Credit Card, please note that the Company neither has access to nor does it store or process Your Transactional Information generated through Your usage of the Scapia Federal Credit Card (either on the Platform or otherwise).

4. User Communication: f 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 (“User Communication”). We retain such User Communication as maybe necessary to resolve disputes, provide customer support, respond to queries, and inquiries, and troubleshoot problems and improve the Platform Services. If You send Us correspondence, such as emails or letters, or if other Users or third parties send Us correspondence about Your activities or postings on the Platform, We may collect and retain such information into a file specific to You for responding to Your request and addressing concerns in relation to Your use of the Platform.

5. Other Information: In addition to the Personal Information, Non-Personal Information, Transactional Information and User Communication, We may also request You to provide other information as and when necessary (“Other Information”). We also seek specific permissions from You such as one-time permissions to use the camera of Your device which enables Us to facilitate the provision of TNPL facility to You, where applicable. The Other Information collected by Us may include inter alia (a) Data either created by You or by a third party and which You wish to store on Our Platform and/or servers such as image files, documents etc.; (b) Data available in public domain or received from any third party including social media channels, including but not limited to Personal or Non-Personal Information from Your linked social media channels (like name, email address, friend list, profile pictures or any other information that is permitted to be received as per Your Account settings) as a part of Your Account information; (c) Information pertaining to any other traveller(s) for who You make a booking through Your Account; (d) copies of government identification like driving license, election card, passport number etc. (as and when required); and (e) such other information as may be reasonably required for the purpose of providing Platform Services to You or as required under any law for the time being in force.

You agree and acknowledge that general permissions sought by You at the time of creating Your Account on the Platform and Your consent thereof for the use of camera of Your device along with location data or any other Personal Information, Non-Personal Information, Transactional Information or Other Information shall be for the provision of Platform Services.

Notwithstanding anything contained in this Privacy Policy or the Terms, Scapia shall, where Your Personal Information, Non-Personal Information or Transactional Information or Other Information is required for facilitating TNPL facility, specifically mention such purpose and acquire Your consent thereof. In no event should You or any third party construe any general consents and permissions granted by You for availing Platform Services on the Platform to be consents/permissions provided for the purpose of availing TNPL facility or for any other financial facility that You may avail on the Platform.

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 of the information disclosed shall lie on Us nor will We be in any way responsible to verify any information obtained from You.

Our primary goal in collecting the aforementioned information is to provide You a safe, efficient, smooth, and customized experience on the Platform. The information collected allows Us to provide the Platform Services and features on the Platform that most likely meet Your needs, and to customize the Platform to make Your experience safer and easier. More importantly, while doing so, We collect the above-mentioned Personal Information from You that We consider absolutely necessary for achieving this purpose.

In general, 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 the Platform Services or a particular feature being provided by Us on the Platform, which requires You to provide such information.

We shall be entitled to retain Your Personal Information and other information for such duration as may be required for the purposes specified hereunder and will be used by Us only in accordance with this Privacy Policy. You acknowledge that if We determine that any information You have provided or uploaded violates the terms of this Privacy Policy, We have the right, in Our absolute discretion, to delete or destroy such information without incurring any liability to You.

2. Use of Information

We use the Personal Information, Non-Personal Information and other information provided by You for the following: (i) to provide and improve the Platform Services and features on the Platform; (ii) to resolve disputes and troubleshoot problems;(iii) to promote Your safety and the safety of other Users or travelers; (iv) to protect the security and integrity of the Platform, the Platform Services and the Users; (iv) to inform You about online and offline offers, products, services, and updates; (v) to customize Your experience on the Platform; (vi) to detect, prevent and protect Us from any errors, fraud and other criminal or prohibited activity on the Platform; (vii) to enforce and inform about Our Terms; (viii) to process and fulfill Your request for Platform Services or respond to Your comments, and queries on the Platform; (ix) to contact You; (x) to communicate important notices or changes in the Platform Services provided by Us or in the use of the Platform and the terms which govern the relationship between You and Us; (xi) to manage and maintain your Account on the Platform; and (xii) for any other purpose after obtaining Your consent at the time of collection.

Separately, in the instance where You avail the Scapia Federal Credit Card, You hereby agree and consent to the Company collecting, storing or process, on behalf of the Federal Bank Limited - Your Personal Information specifically for the purpose of facilitating services in relation to Your Scapia Federal Credit Card. It is hereby clarified that the consent given hereof is separate from the consent provided by You for allowing the Company to collect, store or process Your Personal Information, Non-Personal Information and other information for the purpose of providing Platform Services and for managing Your Account on the Platform.

You also specifically agree and consent to Us collecting, transferring, and sharing information (including Personal Information) related to You with third parties such as with entities registered under applicable laws, payment gateways, etc. solely for providing Platform Services to You including processing Your transactions with the Platform. Where such information is collected for the purpose of facilitating TNPL facility or any other financial facility on the Platform, You may find the list of third parties with whom We share Your information available at https://d1g2rjfi75bg5u.cloudfront.net/third-party-integrations.pdf. We will take Your specific consent in case We wish to share Your information with any other third party and update the aforementioned list.

We may automatically track certain information about You based upon Your behavior on the Platform. We use this information to do internal research on Your demographics, interests, and behavior to better understand, protect and serve You. This information is compiled and analyzed by the Company on an aggregated and anonymized basis and not individually, and in a manner that does not specifically identify You.

We may occasionally ask You to complete optional online surveys. These surveys may ask You for Your contact information and demographic information (like zip code, age, or income level). We use this information to tailor Your experience on the Platform, providing You with content that We think You might be interested in and to display content according to Your preferences. We use Your Personal Information to send You promotional emails, however, We will provide You the ability to opt-out of receiving such emails from Us. If You opt out, We may still send You non-promotional emails, such as emails about the Platform Services and Your Account on the Platform.

3. Sharing of Information:

We may disclose Your Personal Information to Travel Service Providers, third party vendors, partnered institutions, consultants, and such other individuals and/or entities who provide Travel Services through the Platform and 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. You agree and explicitly consent to disclosure of Your Personal Information to such third-parties. This disclosure may be required for Us, for instance, to provide You access to Our Platform Services, or processing payments made by You, or to validate Your bank accounts and Account information, 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 Platform Services.

Additionally, We may disclose Your information, to the extent necessary: (i) to comply with applicable laws and to respond to lawful requests and legal process, (ii) to protect the rights and property of the Company, Our Users, and others, including to enforce the Terms, and (iii) in an emergency to protect the personal safety and assets of the Company, the Users, or any person

We may, in compliance with applicable laws, share/transfer/assign all of Your Personal Information and other information with any other business entity(ies), in the event of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of Our business.

You hereby grant Us consent to share Your information with third parties, as mentioned hereinabove and We shall in no manner be responsible or be under any obligation to inform You or seek additional consent from You for such sharing of information.

Further, You agree and acknowledge that You shall strictly keep all information of other Users received by You on the Platform confidential and shall not disclose such information to any third party unless expressly consented to by the User whose information is being disclosed. In no circumstance whatsoever will We be responsible or liable for any breach of confidentiality by You or other Users on the Platform.

4. 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. We have also adopted security measures in compliance with ISO 27001 and ISO 27701 standards and have received the relevant certifications for the same. 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 Platform Services may not be accessed, disclosed, altered, or destroyed by a breach of any of Our security measures and safeguards. In the event of any actual or suspected security incident, including data breach, We will take all measures required to be undertaken under applicable laws. It is further clarified that You have, for 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.

This Privacy Policy and the security controls and practices implemented by Us to Protect Your Personal Information shall be the reasonable security practices and procedures under section 43A of the Information Technology Act, 2000.

5. Links to Other Third – party Sites and collection of information:

Our Platform may provide links to other third - party Platforms (“Third – Party Sites”) that may collect Your Personal Information including Your IP Address, browser specification, or operating system. We are not in any manner responsible for the security of such information or their privacy practices or content of those Third – Party Sites. Additionally, You may also encounter “cookies” or other similar devices on certain pages of the Third – Party Sites and it is hereby clarified that We do not control the use of cookies by these Third – Party Sites. These third-party service providers and Third-Party Sites may have their own privacy policies governing the storage and retention of Your information that You may be subject to. This Privacy Policy does not govern any information provided to, stored on, or used by these third-party providers and Third-Party Sites. We recommend that when You enter a Third-Party Site, You review the Third-Party Site’s privacy policy as it relates to safeguarding of Your information. You agree and acknowledge that We are not liable for the information published in search results or by any Third-Party Sites.

6. Your Consent and Changes to Privacy Policy:

Withdrawal of consent: You may choose to withdraw Your consent (including regarding the processing, storage and retention of Your Personal Information, Transactional Information or Other Information by Us or by any third party) provided hereunder at any point in time. Such withdrawal of the consent must be sent in writing to privacy@scapia.cards. In case You do not provide Your consent or later withdraw Your consent, We request you not to access the Platform and use the Platform Services. We reserve the right to not provide You Platform Services upon the withdrawal of Your consent. In such a scenario, We may delete Your information or de-identify it so that it is anonymous and not attributable to You. In the event, We retain Your information post the withdrawal or cancellation of Your consent, it shall only be for the period permitted under applicable laws.

Correcting inaccuracies in the information: You may correct or update any information that is provided by You in connection with availing the Platform Services. In the event of loss of access details, You may retrieve the same or receive new access details by sending an e-mail to: care@scapia.cards

Changes To Our Privacy Policy: We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time, by notifying You of such changes. Any changes or updates will be effective immediately. Your continued usage of the Platform post such changes or updates, will serve as Your unqualified acceptance of such changes or updates. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the “Last Updated” legend above.

7. Right to Erasure

You may request the deletion or removal of Your Personal Information, Transactional Information or Other Information which is specifically collected/stored/processed by the Company for the purpose of facilitating TNPL facility or any other financial facility on the Platform. We will comply with Your request as aforesaid where there’s no compelling reason for Us to keep the aforementioned information. Such right of erasure can be exercised by accessing the ‘Your Data’ page on the Platform, and requesting deletion thereof. Alternatively, You may exercise such  right of erasure  by writing to Us at care@scapia.cards. This is not a general right to erasure; there are exceptions, such as when the law requires Us to retain certain Personal Information about You or where such retention is required for providing Platform Services to You, etc. If You intend for Us to not retain Your information for provision of Platform Services, You may exercise Your right to erasure as provided herein and delete Your Account with Us immediately, post which the Company shall not be liable to provide You any Platform Services from the date of such erasure.

8. Data Retention and Deletion

We shall be entitled to retain Your Personal Information, Non-Personal Information and Other Information for such duration as may be required for the purposes specified hereunder or for such other periods as may be required under the applicable laws (“Data Retention Period”) and the said information will be used by Us only in accordance with this Privacy Policy. Notwithstanding anything contained herein, We will not retain your Personal Information and other information for longer than the Data Retention Period. However, We may retain Your information, including but not limited to Your permanent account number, beyond the Data Retention Period the purpose of providing Platform Services to you in a seamless manner. If You intend for Us to not retain Your information beyond the Data Retention Period, You may exercise Your right to erasure as provided for in Clause 7 and De-register Your Account with Us.

However, We may retain information related to You if we believe it may be necessary to prevent fraud or future abuse, to enable Us to exercise our legal rights and/or defend against legal claims or if required by law or for other legitimate purposes. When the retention period for Your Personal Information and Transactional Information, as outlined above expires, We will actively destroy/delete such Personal Information and other information from Our systems. We may, however, continue to retain Your Personal Information in anonymized form for analytical and research purposes.

We will comply with the following procedure for destruction and disposal of Your Personal Information and other information:

• IT department is responsible for deleting or destroying electronic records. This includes ensuring that the Personal Information and other information is permanently removed and from company system and destroyed.

• No Personal Information and other information that are currently involved in, or have open investigations, audits, or litigation pending shall be destroyed or otherwise discarded.

• When retention requirements have been met, Personal Information and other information shall be immediately destroyed.

• The authorized methods of destruction for non-electronic Personal Information and other information are shredding.

You also agree and acknowledge that Scapia may, at its sole discretion, adopt such other mechanisms for the purpose of deleting Your data, as it may deem fit. Such mechanisms may be decided internally without providing You any special notice and You hereby provide Your express and unconditional consent to such mechanisms.

9. Grievance Officer

If You have any grievance with respect to the Platform or the Platform Services , You may write to the grievance officer, the name and contact details have been provided below:

Name: Aniruddh Agrawal

Email: grievance@scapia.cards

Address: 2nd floor, Tower B, Mantri Commercio, Kariyammana Agrahara, Bellandur, Bengaluru, Karnataka 560103, India

We put our best efforts to resolve your grievance in a fair, equitable and timely manner, in compliances with applicable laws.

10. Questions?

Please feel free to contact Us at privacy@scapia.cards regarding any questions on the Privacy Policy.