Last Updated: December 12, 2022

PRIVACY POLICY

Flashmonk Private Limited,CIN No. U72900KA2022PTC157982 (“Company”, "We", "Us", or"Our"), a private limited company with its registered office at 649, KH No 555/649, 13th Cross, 27th Main Road, 1st Sector, HSR Layout Bengaluru Bangalore - 560102, Karnataka, India which owns and operates the website www.flash.co and/or the mobile applicatio the flash.co (collectively referred to as 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. Therefore, We maintain the highest security standards for securing the transactions and Your Information (defined below).    

This privacy policy (“Privacy Policy”) specifies the manner in which Your personal data and other information is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company in relation to the services offered on the Platform (“Services”). 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 services offered on the Platform.

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

By clicking the “Continue” button provided at the sign-up page for the Platform, users (You”, “Your” as applicable) accept and agree to be bound by the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into 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) from You when You register or set up an account with Us or login on the Platform. You may browse certain sections of the Platform without being registered with Us. However, to avail the 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: When You start using the Platform, You may provide certain information to Us voluntarily while registering on Our Platform for availing Our Services, such as mobile number, Permanent Account Number (PAN), signature, email address, date of birth, photograph (selfie), identity and address proof such as passport, driver’s license, voter ID, or any other government issued identity proof document, communication and residential address details, location and source of income, etc. We will collect this information through various means and in various places through the Platform, including account registration forms, contact us forms, or when You otherwise interact with the Platform including at customer support. 

We may also ask You for certain financial information, including Your bank account details and type, Unified Payment Interface (UPI) ID, Indian financial system code (IFSC) of Your bank, and/or other payment related details or other payment method data, and debit instructions to process payments. 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 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.

Certain features of the Platform may be restricted, unavailable or unusable if You choose not to provide certain information. 

The above information is collectively referred to as (“Personal Information”). 

  1. Location based information: When and if You download and/or use the Platform through Your mobile or computer, We explicitly seek permissions from You to get the required information from such device. We may receive information about Your location, Your Internet Protocol Address (“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 the Platform. In addition to the above, We identify and use Your IP Address to also help diagnose problems with Our server, resolve such problems and administer the Platform. Your IP Address is also used to help identify You and to gather broad demographic information.
  1. SMS information:After obtaining Your specific consent to allow the Platform to access Your SMS inbox and contacts, We may collect relevant information from text messages (SMS) received by You from providers of services and/or products in relation to e-commerce transactions and such other information as may be required to provide better access to Our Services to You. 
  1. Electronic mail (e-mail) information: When you link your email (either Flash.Co ID or email provided by any other third party email service providers) to the Platform and/or create a Flash.Co ID on the Platform, We may access such email accounts and collect data in relation to e-commerce transactions. We may also collect and securely store Your email account details, including Your login credentials, e-mails received in your email account (including any attachments thereto, the email meta data, etc.). We only read emails related to electronic commerce shopping such as order value, shipment delivery, order details, biller details etc., and do not read or access any personal emails. For the sake of clarity, the Company employs automated processes for accessing and analyzing information from Your linked e-mail accounts and no humans are allowed to access or read your emails. You can provide Us access to one or more of Your e-mail accounts by connecting such emails to the Platform. 
  1. Non – Personal and Automatic Information: We may also collect certain non-personal information, such as Your IP Address, web request, operating system, browser type, URL, internet service provider, aggregate user data, software and hardware attributes, pages You visit, and cookie information, etc., which will not identify You specifically (“Non-Personal Information”), while You browse, access or use the Platform. We receive and store Non–Personal Information by the use of data collection devices such as “cookies” on certain pages of the Platform, in order to help and analyze Our Platform flow, track user trends, measure promotional effectiveness, and promote trust and safety. We offer certain additional features on the Platform that are only available through the use of a “cookie”. We place both permanent and temporary cookies in Your computer/mobile device’s storage drive.
  1. User communications: 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. 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.

Your Personal Information, Non-Personal Information and other information listed above shall together be referred to as “Your Information”. 

All information gathered by the Company shall be stored on servers, log files and any other storage system owned by the Company or by third parties in India. Our primary goal in doing so is to provide You a safe, efficient, smooth, and customized experience on the Platform. 

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. More importantly, while doing so, We collect Your Information from You that We consider necessary for achieving this purpose.

We also use cookies to allow You to enter Your password less frequently during a session on the Platform. Most cookies are “session cookies,” meaning that they are automatically deleted from Your storage drive at the end of a session. To provide a better experience to You, We also store certain “session cookies” on Your device, so that You do not lose Your last browsed page and can continue using the Platform seamlessly in case of network outage or unexpected sign out from the Platform. You are always free to decline Our cookies if Your browser permits, although in that case, You may not be able to use certain features or Services being provided on the Platform or You may be required to re-enter Your password each time You log – in or access the Platform during a session.

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 a particular Service, which requires You to provide such information. 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 basis and not individually, in a manner that does not specifically identify You.  

We shall be entitled to retain Your 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 Your Information without incurring any liability to You.

You hereby agree, acknowledge and grant Your consent enabling Us to retain any information provided by You for Our compliance under applicable laws including but not limited to the Prevention of the Money Laundering Act, 2002 or the Prevention of Money Laundering (Maintenance of Records) Rules, 2005 as amended, modified/ reenacted from time to time and/ or any other guidelines/policies issued by government/ statutory authorities or any regulatory bodies in this regard. 

  1. Use of information:

We use Your Information, for the following: (i) to provide order tracking facility; (ii) to curate offers and rewards specifically for You; (iii) to provide an insight into Your shopping pattern(s) in order to ensure that You are aware of Your spends pattern so that You make wiser decisions; (iv) to provide and improve the Services and features on the Platform that You request; (ii) to resolve disputes and troubleshoot problems; (v) to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users; (vi) to inform You about online and offline offers, products, services, and updates; (vii) to provide an insight into Your spending pattern(s); (viii) to calculate and display rewards earned from various transactions; (vii) to customize Your experience on the Platform or share marketing material with You; (ix) to detect, prevent and protect Us from any errors, fraud and other criminal or prohibited activity on the Platform; (x) to enforce and inform about our terms and conditions; (xi) to process and fulfil Your request for Services or respond to Your comments, and queries on the Platform; (xii) to contact You; (xiii) to communicate important notices or changes in the Services provided by the Company, use of the Platform and the terms which govern the relationship between You and Us; (xiv) for any other purpose after obtaining Your consent at the time of collection; and (xv) sharing and disclosure of data with third parties. Any collection of additional information and documents shall be subject to Your consent. We allow You to use Your Flash.Co ID to sign-in or log-in to third party websites or applications or platforms. Upon signing-in or logging-in to such third-party websites or application or platforms we will share certain basic Personal Information  about You with such third party.  Do note, the processing of such Personal Information shall be subject to the terms of use and privacy policy of such Third Party and we request You to read the same before using Your Flash.Co ID for such sign-up or login.

You also specifically agree and consent to Us collecting, storing, processing, transferring, and sharing Your Information with third parties such as with entities registered under applicable laws, with third party payment gateways, etc., solely for the purpose of providing Services to You (including processing Your transaction requests for the Services).

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 etc.,). We use this information to tailor Your experience at 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, the Company may still send You non-promotional emails, such as emails about the Services and Your Account on the Platform. 

  1. Sharing of Information:

Access to Your Personal Information will be provided to certain of Our employees strictly on a need-to-know basis. With Your consent, We may also disclose Your Personal Information to third party vendors, partnered organizations, consultants, and other service providers who work for the Company or provide 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. This disclosure may be required for Us, for instance, to provide You access to Our Services including for processing redemption of rewards for gift vouchers, gift cards, fiat currency etc., 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. 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: (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. In such an event the Company is in no manner responsible for informing You or seeking Your approval or consent.

We may, in compliance with applicable laws, share/transfer/assign all of Your 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. 

  1. 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 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. While We will have in place adequate security protocols in place, We request You to ensure that at all times You secure and have in place adequate security protocols to protect Your Information against any unauthorized access.

Our use of Your Information received from Your Gmail accounts through Google APIs will adhere to Google API Services User Data Policy, including the limited use requirements. 

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

  1. 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. The Company is 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 by the Company that it does 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.

  1. Manage access to Your Gmail Account

You can manage access to Your Gmail account and review the access provided to Us (including the account access, access to You Google services, etc.,) by going to the ‘security section’ of Your Google account. 

To learn more about how Google helps users share their data safely, please visit: https://support.google.com/accounts/answer/10130420?hl=en

  1. Public Posts: 

You may provide Your feedback, reviews, testimonials, etc. on the Platform on Your use of the Services provided by the Company (“Posts”). Any content or Personal Information and Posts that You share or upload on the publicly viewable portion of the Platform will be publicly available, and can be viewed by other users. Your Posts shall have to comply with the conditions relating to use of Platform as mentioned in the Terms. The Company retains an unconditional right to remove and delete any Post or such part of the Post that, in the opinion of the Company, does not comply with the conditions in the Terms. The Company reserves the right to use, reproduce and share Your Posts for any purpose. If You delete Your Posts from the Platform, copies of such Posts may remain viewable in archived pages, or such Posts may have been copied or stored by other Users.

  1. Your Consent and Changes to Privacy Policy:

Withdrawal of consent: You may choose to withdraw Your consent provided hereunder at any point in time. Such withdrawal of the consent must be sent in writing to support@flash.tech. In case You do not provide Your consent or later withdraw Your consent, We request You not to access the Platform or use the Services and also reserve the right to not provide You any Services on the Platform. In such a scenario, the Company may delete Your Information or de-identify it so that it is anonymous and not attributable to You. In the event, the Company retains the Personal Information post withdrawal or cancellation of Your consent, it shall retain it only for the period permitted under applicable laws.

Correcting inaccuracies in the information: You may correct or update any information online. In the event of loss of access details, You may retrieve the same or receive new access details by sending an e-mail to: support@flash.tech 

Right to Erasure:  This is also known as ‘the right to be forgotten’ and, in simple terms, enables You to request the deletion or removal of Your Information where there’s no compelling reason for Us to keep it. Such right of erasure can be exercised by writing to Us at support@flash.tech. 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 the Services to You, etc.

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. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the “Last Updated” legend above. 

  1. Data Retention and Deletion

We shall be entitled to retain Your 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 and the said information will be used by Us only in accordance with this Privacy Policy.  However, We may retain Your Information 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 as outlined above expires, We will actively destroy/delete such Personal Information from our systems. We may, however, continue to retain Your Personal Information in anonymized form for analytical and research purposes.

  1. Grievance Officer:

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

Name: Sugath Suredran

Email: Sugath@flash.tech

  1. Questions?

Please feel free to contact us at support@flash.tech regarding any questions on the Privacy Policy.