Privacy Policy

Privacy Policy

This privacy policy applies to the entire contents of the platform “Xpesa” operated by Renaissance Digital Solutions Pvt Ltd. [“Xpesa”] which may be referred to hereon in as “we” or “us” or “our” (as applicable)] including, without limitation, website or any application or software used to access the platform (“Website” or “mobile application or app”).

Please read the Privacy Policy below carefully before using Xpesa. By using or registering on Xpesa, you accept and agree to the terms of this Privacy Policy. If you do not accept these terms, you will not be allowed to access Xpesa.

The Users are responsible for ensuring that we keep their information current and accurate. The User shall update their information by contacting us at support@xpesa.io, and we will use reasonable efforts to process any change the User seeks to make; provided, however, that requests to delete information are subject to Xpesa’s internal reporting, processing and retention policies and all applicable legal obligations and existing legislations.

We at Xpesa are committed to preserving the privacy of all visitors to our platform Xpesa. We are committed to ensuring that all services and activities made available via the platform Xpesa will be provided in a safe and secure online environment. By accepting Xpesa’s Privacy Policy and the Terms & Conditions at the time of registration, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is effective upon acceptance in registration for new registering users. This Privacy Policy is incorporated into and subject to Xpesa’s ‘Terms of Use’. This Privacy Policy is effective upon acceptance in registration for new registering users.

Please read the following carefully to understand our views and practices regarding the User Information. The Privacy Policy can be found on our platform at https://xpesa.io/privacypolicy.php

Your Privacy: Our Commitment
At Xpesa, we are extremely proud of our commitment to protect your privacy and recognise that you have a right to know about the information we access or collect about you, how your information is being used by us and what we do to protect your information. Please read the following policy to understand how your personal information shall be treated by Xpesa.

Our commitment towards privacy and protection of User data is based on the principles of lawfulness, transparency, fairness, accuracy, data minimisation, integrity and confidentiality.

What does this Privacy Policy Cover?

This Privacy Policy is part of the Xpesa’s Terms of Use and covers the treatment of user information, including personally identifying information, obtained by Xpesa including information obtained when you access the Xpesa’s Website and/or Mobile Application or any other software provided by Xpesa and any information that you may share through use of the Xpesa’s Website and/or Mobile Application.

Introduction

  • Xpesa (“Xpesa we us”) recognizes that people who use Xpesa’s service (“you” or “User”) value their privacy. This Privacy Policy details important information regarding the collection, use and disclosure of User information collected on Xpesa’s website located at www.xpesa.io(collectively referred to as “Site”), the related mobile app, and any other features, tools, materials, or other services (including co-branded or affiliated services) offered from time to time by Xpesa or its affiliate companies (the “Service”). Xpesa provides this Privacy Policy to help you make an informed decision about whether to use or to continue using the Service.
  • This Privacy Policy should be read in conjunction with our Terms & Conditions. By accessing the Site and/or Service, you are consenting to the collection and use of information practices described in this Privacy Policy.
  • The User’s use of the Site and/or Service and any information the User may provide through the Site and/or Service remains subject to the terms of this Privacy Policy and our Terms of Use, as each may be updated from time to time.
  • User, through access of the Service and acceptance of this Privacy Policy, hereby warrants and accepts that he/she has given his/her explicit and unequivocal consent to Xpesa for collection and processing of his/her personal information and that the said collection and processing of his/her personal information is necessary for Xpesa to fulfil their obligations for the provision of Services to the said User/player and User’s/player’s access to the said Services on our platform.
  • Any questions, comments or complaints that you might have should be emailed or forwarded in writing at: support@xpesa.io
  • Information Collected from the Users
  • Third Party Sites & The User
  • Use of Information by Xpesa
  • Sharing of Information
  • Monitoring of Transactions & Customer Support
  • User’s Choices
  • Third Party Sharing, Advertising and Analytics
  • User Rights under this Privacy Policy
  • Information Security
  • Unsubscribing to Communications
  • Privacy Measures for Minors
  • Legal Compliance
  • Changes and Updates for Information
  • Applicable Law & Jurisdiction
  • Language

Information Collected from the Users

By choosing to use our Site and/or Service and by submitting information to us through your use of our Site and/or Service the User hereby warrants and accepts that this Privacy Policy, will apply to the User. You provide certain personal information to Xpesa when choosing to participate in the various activities on the Site and/or Service, such as registering for an account, details for verification, input(s) during trading on the Xpesa, financial details, contact information, posting messages, taking advantage of promotions, responding to surveys or subscribing to newsletters or other mailing lists.

  • Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.
  • Process“, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • The information may be collected from the User in a number of ways which may include collecting personal information if the User chooses to create an account with us, thereby agreeing with the Terms of Use and accepting the Privacy Policy of Xpesa while using the Site and/or Service. The User may also be required to complete an online survey or feedback form, sign up or email us to receive communications from us. We may also ask the User to provide information regarding his/her contact details including name, email address, mailing address, telephone number, age, gender, date of birth, credit card & billing information, profile picture, username, locations, responses to surveys, communications sent by you to us etc.
  • In addition to the above, we may need to verify your identity in order for you to use some aspects of the Site/ Service. For purposes of verification, we may also collect the following personal information from you:
    • Passport information;
    • Aadhar Card information and details;
    • PAN Card information;
    • Government-issued residence proof;
    • User´s bank account details and proof of the same;
    • Tax-related information; and
    • Other information as may be required to verify you in accordance with applicable laws and regulations.
  • We may require you to furnish information about the payment methods such as credit/debit cards, e-wallets and other online payment methods. We may also require you to furnish additional information, about the same including but not limited to, billing address, card type, number, expiration date, card security code etc. If you choose to access any the Site and/or Service of Xpesa which requires payments, you may be required to furnish the above stated details.
  • When you use our mobile app, you hereby consent to us accessing the features of your mobile device such as the phone number, your contacts, IMEI number of your device, whether a phone call is active, the number that the phone call is connected to and the like. The access to your mobile phone device features is used to stop the radio commentary and terminate the internet access when you make or receive a call without any disruption.
  • When you use our mobile app, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device (such as IDFA or an Android Ad ID), device information, default device language, the location of your device (at a GPS level), and app usage information. This data also may be linked to your other information, including your location data.
  • In addition, if you choose to log in, access or otherwise connect to Xpesa or contact Xpesa through a social networking service or any third party service (such as Facebook, Twitter, Instagram, Google etc.), we may collect your user ID and/or user name associated with that social networking service or third party service, as well as any information you make public using that social networking service or third party service. We may also collect information you have authorized the social networking service or third-party service to share with us (such as your user ID, public profile information, email address, birthday, friends list, and pages you have “liked” or tweeted).
  • We may collect and process the information such as names, photos, contact details, the User’s activity during the posts and comments pertaining to Xpesa.
  • Cookies Information: When you visit the Xpesa Site, we may send one or more cookies – small files – to your computer or other device, which may enable us or others to uniquely identify your browser. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
  • Xpesa may use both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. Session cookies are temporary and typically disappear after you close your browser. You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Site or Service may not function properly if the ability to accept cookies is disabled.
    We use the session cookies to keep track of you whilst you navigate the Site/Service to prevent frauds and increase website security. We use the persistent cookies to enable our Site to recognize you when you visit and keep track of your preferences in relation to your usage of our website.
    We may use Google Analytics to analyze the usage of this Site/Service. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our Site/Service is used to create reports about the use of the Site/Service. Google will store this information and Google’s privacy policy is available at:
    <http://www.google.com/privacypolicy.html>.
    You can manage your preferences relating to the use of cookies on our Site/Service by visiting < https://xpesa.io/>. Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third-party cookies. For example, in Internet Explorer (version 9) you can refuse all cookies by clicking “Tools”> “Internet options”> “Privacy” and selecting “Block All Cookies” using the sliding selector. Blocking all cookies may, however, have a negative impact upon the utility and/or efficacy of many websites including our Site/Service.
  • Log File Information: When you use our Service, our servers may automatically record certain information that your device sends whenever you visit any website and use certain apps. These server logs may include information such as your web or app request, Internet Protocol (“IP”) address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, the actions you take on a page and one or more cookies that may uniquely identify your browser.
  • Clear GIFs Information: When you use our Service, we may employ technology such as “clear GIFs” (a.k.a. Web Beacons) which are used to track the online usage patterns of our User(s). In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by specific users.

Third Party Sites & The User

  • Xpesa Site and enter a third-party site through the Xpesa Site, use of any information you provide shall be governed by the privacy policy and/or terms and conditions of the operator of the particular third-party site you are visiting. Xpesa shall not, under any circumstances, be responsible for any use of third-party site by such User.
  • Xpesa refuses to acknowledge or represent the accuracy, completeness, reliability or adequacy of the Site’s third-party content. The content, materials, information, services and products in the Site including text, graphics and links, are provided “AS IS” and without warranties of any kind, whether expressed or implied. Xpesa is in no way responsible for any content of any linked site or any link contained in a linked site.
  • Xpesa disclaims all warranties, expressed and implied with regards to the merchantability and fitness of the Site and/or such third-party sites for a particular purpose. Xpesa also does not guarantee that users shall be able to use the Site and/or such third-party websites without any interruption, which may lead to loss in continuity.
  • Although, Xpesa shall make reasonable efforts to ensure that the Site remains free of viruses or other harmful components, however, Xpesa does not in any way represent or warrant that the Site or the server that makes the Site available shall be free of such harmful components. Use of the services of this Site is at User’s own risk and Xpesa shall not be responsible for any servicing costs, repair or correction of the User’s systems.
  • Xpesa does not, in any manner whether express or implied, endorse the advertisements hosted on its Site and the Users responding to such advertisements and/or purchasing any products advertised on Xpesa hereby warrant and accept that they shall do so at their own risk.
  • Xpesa reserves all rights to the assets, content, services, information and products and graphics in the Site except any third-party content.

Use of Information by Xpesa

  • We may use your personal information to operate and maintain the Site/Service. The information may also be used to provide, to you, the features and functionality of the Site/Service, including but not limited to the following:
    • administering the Site/Service and enabling its use for the User;
    • providing you with our products, services etc.;
    • processing and responding to your enquiries or feedback;
    • personalizing your use of the Site/Service,
    • alerting you to new features, special events, products and services, or certain third-party products or services in which we think you will be interested;
    • sending statements and invoices to you and collecting payments from you;
    • dealing with customer inputs, complaints and suggestions;
    • enforcing the legal terms and conditions that govern your use of the Service; and
    • contacting you about your account or profile.
  • We may use your information (both personal and non-personal information) to send you marketing and advertising content, including sending you advertising through multiple channels, such as direct mail, email, push notifications and display media. We may send you advertising or content regarding our products and services, or products and services that we market on behalf of another company or any other entity.
  • We may use your information to communicate with you about:
    • our products and services in which you may be interested provided that you have not requested otherwise;
    • newsletters and information for which you have signed up; and
    • non-marketing or administrative purposes (such as notifying you of major changes to the Site/Service or for customer service purposes).
  • We use your information to improve the quality and design of our Site/Service and to create new features, promotions, functionality, and services such as by storing, tracking, and analyzing user preferences and trends.
  • We may use the information collected from you in order to process payment(s) and fee(s).
  • We may use your information in order to implement sufficient credit fraud protection and/or risk reduction measures.
  • We also use cookies, clear gifs, log file information, and mobile app information such as device identifiers for purposes such as (a) remembering information so that you will not have to re-enter it during your visit or the next time you use our Service; (b) providing custom, personalized content and information; (c) monitoring the effectiveness of our marketing campaigns; (d) monitoring aggregate metrics such as total number of visitors, pages viewed, etc.; and (e) tracking your entries, submissions, and status in promotions. You can learn more about how these technologies are used in the Section below, ‘Third Party Advertising and Analytics’.
  • We may anonymize, de-identify, or aggregate your information for any legitimate business purposes, including for reporting and research, or advertising. Such anonymized and/or aggregated data does not personally identify you. Sometimes, this information may be used to target more relevant content or offers to you across different devices – for instance, we may provide you with offers and content on your mobile device, based on your web-based activity.
  • We may use the information collected from you to verify User compliances with the Terms and Conditions and/or Privacy Policy governing the use of the Site/Service including monitoring private messages sent through our Site/Service private messaging service (if available). Your privacy settings can be used to limit the publication of your information on the Site/Service. You can adjust your privacy settings by contacting us at < support@xpesa.io>.
  • We may disclose the information provided to us by the User for any other reason the User provided us with the said information.
  • We may upload the information provided by you (including contact details) to <xpesa.io> and/or any other Xpesa’s backend server(s) for providing you with Service.

Sharing of Information

  • All User information collected by us through the Site shall be protected and not consciously shared with any third parties other than in the following circumstances:
    • Shared with Xpesa’s affiliate and associated entities for marketing and advertising requirements in relation to our services;
    • Shared with those who provide to us or affiliate entities products or services that support the services that we provide;
    • anyone we transfer our business to in respect of which you are a customer or a potential customer;
    • To comply with applicable State/Central regulations including but not limited to sharing with appropriate tax authorities;
    • To protect the security or integrity of our Service
    • If required by governmental, regulatory or law enforcement agencies; and
    • If required by law to be supplied to any entity.
  • If you elect to participate in any promotions, surveys, questionnaires, or other events during your usage of Xpesa, the rules or terms and conditions for those events may indicate that your information will be shared with third parties with your consent. You are advised to review the applicable rules and/or terms and conditions for any promotions, surveys, questionnaires or events.
  • In the event that Xpesa is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, or other change of control, there may be a disclosure of your personal information to another entity related to such event.
  • In the event ownership or control of Xpesa Site/Service is acquired by a new owner, your information may be transferred to the new owner as such a transfer may be necessary for the continued operation of Xpesa Service. Any changes to this Privacy Policy by the new owner shall be notified on the Xpesa platform.

Monitoring of Transactions & Customer Support

  • All account transactions are recorded on our computer system. We also carry out routine monitoring of all transactions as they take place, to assist us in improving the Service, we provide to you.
  • All telephone conversations from the User(s) to our Customer Support Centre, may be recorded, to assist us in training, quality management and to allow for the speedy resolution of the queries.
  • All communications with Xpesa and its Customer Support shall be conducted in parliamentary language (language which is not offensive and/or abusive). Xpesa prevents and prohibits any such use of offensive and/or abusive language and strictest of actions shall be taken against the User who uses such offensive and/or abusive language including but not limited to suspension and/or termination of the User Account.

User’s Choices

  • Xpesa will process your personal information in accordance with this Privacy Policy and shall provide you with choices vis-à-vis processing of your personal information as set out below:
    • You can access and update certain personal information Xpesa holds about you at any time by logging into your account via the Site/Service. You can update your marketing preferences and whether you or not would like us, to send you newsletters in your account. You can also unsubscribe to marketing emails and newsletters by using the ‘unsubscribe’ feature in the communication.
    • We may occasionally send visual media to you, in a targeted way, whether through web or mobile browsers or mobile applications. You may unsubscribe to such visual media displays by emailing us at support@xpesa.io. You may opt out of tracking for mobile advertising through the settings on most smartphones, and you may learn more about these settings through those mobile device platforms, i.e., Google ((https://support.google.com/ads/answer/2662922?hl=en)) and Apple (https://support.apple.com/en-in/ht202074). (Please note that these companies may change either the way these settings operate, the content or the availability of these pages.)
    • We may occasionally send you push notifications to your mobile device. You can turn off certain push notifications in the account settings of your Xpesa Account. You can also turn off push notifications specific to our Service in the settings on your mobile device.

Third Party Sharing, Advertising and Analytics

  •  Certain advertisements that may appear on our Service are delivered by our advertising partners. Our advertising partners may use cookies and other similar technologies, often in conjunction with unique (anonymous) cookie identifiers, to collect data about your activities and interests, including the technologies described above. Some of these partners may use mobile device identifiers, such as Apple IDFAs and Google/Android Advertising IDs. Doing this allows the ad companies to recognize your computer or device each time they send you an online or mobile advertisement. In this way, the advertisement companies may compile information about where you, or others who are using your computer or device, saw their advertisements and measure your interaction with each advertisement. This information allows advertisement companies to deliver targeted advertisements that may be of increased interest to you, both on our Site/Service and elsewhere online. Just as these technologies may be used to target ads on our websites and apps, we, or our advertising partners, may use these same technologies and data points (e.g., mobile identifiers, cookie identifiers, location-based data), through our Service or through other services, to target advertising (for ourselves or other companies) on other sites or mobile apps. Sometimes, these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising as well, for instance, to evaluate which ads or content our users prefer, or which are most effective. In addition, sometimes we or an advertising partner may tailor advertising to you across different devices.
  • Xpesa may disclose the information it collects about the User to:
    • to its service providers, to its affiliates, sponsors, suppliers and others who help provide the platform to the User;
    • to licensors, activity and event partners and other third parties for their own marketing purposes, such as to provide information to the User about their new developments, special events, programs, services, activities, products, attractions, promotions and other important information;
    • third parties to provide analytics or to confirm/update information provided by the User;
    • third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of the M/s Renaissance Digital Systems Pvt. Ltd. business or other operations (including without limitation in connection with bankruptcy or any similar proceedings); and
    • or as otherwise authorized by the User.
  • We may also share the User’s personal information in response to a legal order or official request; when we believe the User have acted in violation of the Terms & Conditions of Xpesa; to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats; to exercise legal rights or defend against claims; or as otherwise permitted or required by law.
  • We also may use, share or sell non-personally identifiable information with third parties. Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified form with advertisers, business partners, and/or third parties in order to analyze usage of the Site/Services in order to improve our services and the User experience or for any similar purposes. Such data shall not be re-identified and the contracting parties would be asked to agree to keep the data in its de-identified form after such use.
  • If the User elects to participate in any promotions, surveys, questionnaires, or other events during his/her visit to Xpesa, the rules or terms and conditions for those events may indicate that the User’s information will be shared with third parties with his/her consent. The Users are advised to review the applicable rules and/or terms and conditions for any promotions, surveys, questionnaires or events.

User Rights under this Privacy Policy

  1. Right to withdraw consent
    1. The User shall have the right to withdraw his or her consent at any time with respect to the processing and disclosure of the personal data/information provided to Xpesa.
    2. Such withdrawal of consent shall not affect the lawfulness of any processing/disclosure based on User consent carried on by Xpesa before its withdrawal.
  2. Right to Transparency and Communication
    1. Xpesa shall take appropriate measures to provide any information referred to in this Privacy Policy and any communication under this Privacy Policy relating to processing to the User in a concise, transparent, intelligible and easily accessible form, using clear and plain language. Such information shall be provided in writing, or by other means, including, where appropriate, by electronic means. When requested by the User, the information may be provided orally, provided that the identity of the User is proven by other means.
    2. Xpesa shall facilitate the exercise of User’s rights under this Clause (User Rights under this Privacy Policy) and offer full co-operation and support towards the same.
    3. Xpesa shall provide information on action taken on a request under this Clause (User Rights under this Privacy Policy) to the User without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. Xpesa shall inform the User of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the User makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the User.
    4. If Xpesa does not take action on the request of the User, Xpesa shall inform the User without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
    5. Information provided under this Clause (User Rights under this Privacy Policy) and any communication and any actions taken under this Clause and Privacy Policy shall be provided free of charge. Where requests from a User are manifestly unfounded or excessive, in particular because of their repetitive character, Xpesa may either:
      1. charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
      2. refuse to act on the request. Xpesa shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.
      3. Without prejudice to this Clause, where Xpesa has reasonable doubts concerning the identity of the natural person making the request referred to herein, Xpesa may request the provision of additional information necessary to confirm the identity of the User.
    6. Without prejudice to this Clause, where Xpesa has reasonable doubts concerning the identity of the natural person making the request referred to herein, Xpesa may request the provision of additional information necessary to confirm the identity of the User.
  3. Right to information
    1. Where personal data relating to a User are collected from the User, Xpesa shall, at the time when personal data are obtained, provide the User with all of the following information:
      1. the identity and the contact details of Xpesa and, where applicable, of the Xpesa’s representative;
      2. the identity and the contact details of Xpesa and, where applicable, of the Xpesa’s representative;
      3. the recipients or categories of recipients of the personal data, if any;
      4. categories of personal data concerned;
      5. where applicable, the fact that Xpesa intends to transfer personal data to a third party, third country or international organization.
    2. In addition to the information referred to in sub clause (i) above (under Right to Information), Xpesa shall, at the time when personal data are obtained, provide the User with the following further information necessary to ensure fair and transparent processing:
      1. the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
      2. where the processing is based or would be carried out;
      3. the existence of the User’s right to request from Xpesa access to and rectification or erasure of personal data or restriction of processing concerning the User or to object to processing;
      4. the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
      5. whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the User is obliged to provide the personal data and of the possible consequences of failure to provide such data.
    3. Where Xpesa intends to further process the personal data for a purpose other than that for which the personal data were collected, Xpesa shall provide the User, prior to that further processing, with information on that other purpose and with any relevant further information as referred to in sub clause (ii) above (under Right to Information).
    4. The above stated provisions under sub-clauses (i), (ii) and (iii) above (under Right to Information) shall also apply where Xpesa intends to collect information from the User.
  4. Right to access to data
    1. The User shall have the right to obtain from Xpesa confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
      1. the purposes of the processing;
      2. the categories of personal data concerned;
      3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
      4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
      5. the existence of the right to request from Xpesa rectification or erasure of personal data or restriction of processing of personal data concerning the User or to object to such processing;
      6. where the personal data are not collected from the User, any available information as to their source;
    2. Where personal data are transferred to a third party, third country or to an international organisation, the User shall have the right to be informed of the appropriate safeguards implemented by Xpesa.
    3. Upon request by the User, Xpesa shall provide a copy of the personal data undergoing processing. For any further copies requested by the User, Xpesa may charge a reasonable fee based on administrative costs. Where the User makes the request by electronic means, and unless otherwise requested by the User, the information shall be provided in a commonly used electronic form.
  5. Right to rectification
    The User shall have the right to obtain from Xpesa without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the User shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  6. Right to erasure (Right to be forgotten)
    1. The User shall have the right to obtain from Xpesa the erasure of personal data concerning him or her without undue delay and Xpesa shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
      1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
      2. the User withdraws consent on which the processing is based and where there is no other legal ground for the processing;
      3. the User objects to the processing pursuant to Clause I (Right to object) below and there are no overriding legitimate grounds for the processing;
      4. the personal data has been unlawfully processed;
      5. the personal data have to be erased for compliance with a legal obligation under any law to which Xpesa is subject.
    2. Where Xpesa has made the personal data public and is obliged pursuant to sub clause (i) above ((under Right to erasure (Right to be forgotten)) to erase the personal data, Xpesa, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform entities which are processing the personal data that the User has requested the erasure by such entities of any links to, or copy or replication of, those personal data.
    3. Sub-clauses (i) and (ii) above ((under Right to erasure (Right to be forgotten)) shall not apply to the extent that processing is necessary:
      1. for exercising the right of freedom of expression and information;
      2. for compliance with a legal obligation which requires processing by any law to which Xpesa is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in Xpesa;
      3. for the establishment, exercise or defence of legal claims.
  7. Right to restriction of processing
    1. The User shall have the right to obtain from Xpesa restriction of processing where one of the following applies:
      1. the accuracy of the personal data is contested by the User, for a period enabling Xpesa to verify the accuracy of the personal data;
      2. the processing is unlawful, and the User opposes the erasure of the personal data and requests the restriction of their use instead;
      3. Xpesa no longer needs the personal data for the purposes of the processing, but they are required by the User for the establishment, exercise or defence of legal claims;
      4. the User has objected to processing pursuant to Clause I (Right to object) below pending the verification whether the legitimate grounds of Xpesa override those of the User.
    2. Where processing has been restricted under sub clause (i) above ((under Right to restriction of processing), such personal data shall, with the exception of storage, only be processed with the User’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights.
  8. Right to data portability 

    The User shall have the right to receive the personal data concerning him or her, which he or she has provided to Xpesa, in a structured, commonly used and machine-readable format and have the right to transmit those data to another entity/body without hindrance from Xpesa.

  9. Right to object
    1. The User shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her including profiling. Xpesa shall no longer process the personal data unless Xpesa demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedom of the User or for the establishment, exercise or defence of legal claims.
    2. Where personal data are processed for direct marketing purposes, the User shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
    3. Where the User objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
  10. Users from Excluded Locations
    1. The Excluded Location shall be defined as the Countries/regions other than the territory in which it is legally provided and Excluded territories where the services of Xpesa shall not be offered and accessed and/or are prohibited to be offered and accessed by the users.
    2. If you are a user accessing our Service from any Excluded locations with laws or regulations governing personal data collection, use, and disclosure, your continued use of the Xpesa Service shall amount to your express and implied consent to the transfer of your personal information to Xpesa as per applicable laws and regulations.

Information Security

  • We are committed to protecting the security of your personal information. Protection of the User Information, including the registration details or any other payment information the User provides to us, is a priority for us. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.
  • Any personal information which identifies the User will be encrypted at all times whilst in transit over the internet. The technology used by us encrypts any information sent by the User on secured pages. Our server then reads the information using a private key. This means that your information, be it any payment information provided to us or any other personal details, is turned into a code that can only be decoded with the private key or password.
  • Whilst neither we, nor any other organization, can guarantee the security of information processed online, we do have appropriate security measures in place to protect your personal information. For example, we store the personal information you provide on computer systems with limited access that are located in facilities to which access is limited.
  • To further protect your privacy and security, we reserve the right to take reasonable steps (such as requesting your password) to verify your identity before granting you profile access or making corrections.
  • Additionally, you should ensure your password is kept secret at all times. You will be responsible for maintaining the secrecy of your password and account information.

Unsubscribing to Communications

  • If the User does not want to receive any e-mails from us in the future, they are required to let us know by dropping an email to us. We will use our reasonable endeavours to remove the User’s name from the related mailing list within fourteen (14) working days of his/her request. The User may also change his/her preferences at any time by revising his/her account profile by un-ticking the boxes for the previously opted communications.
  • The User may also click the “unsubscribe” link (if present) at the bottom of any emails he/she may receive from us and follow the necessary instructions provided.

Privacy Measures for Minors

  • Xpesa is intended for persons who are eighteen (18) years of age or above. If the User is under eighteen (18) years of age, he/she shall not be permitted to use the platform ‘Xpesa’.
  •  If the User is a parent and/or guardian and believe that we may have inadvertently collected personal information from their child, they can notify us immediately by sending an email to: support@xpesa.io

Legal Compliance

  • Xpesa and its owners take a proactive approach to User privacy and ensure that all reasonable steps are taken to protect the privacy of its Users throughout their visiting experience.
  •  Xpesa website and/or app complies with all relevant laws for User privacy, specifically this policy has been made pursuant to the provisions of the applicable Information Technology laws and regulations.

Changes and Updates for Information

  • This Privacy Policy may be revised periodically and this will be reflected by the “Last update posted” date above. Please revisit this page to stay aware of any changes. If there is a revision to this Privacy Policy, which is material, we will notify you by contacting you through the email address associated with your User account.
  •  Contact Information: Please contact Xpesa with any questions or comments about this Privacy Policy by emailing us at support@xpesa.io
  • The User is responsible for keeping his/her information current. The User may update his/her information by contacting us at support@xpesa.io and we will use reasonable efforts to process any change the User makes; provided, however, that requests to delete information are subject to our internal reporting, processing and retention policies and all applicable legal obligations.

Applicable Law & Jurisdiction

Xpesa is created and controlled by M/s Renaissance Digital Systems Pvt. Ltd. in India. As such, the laws of India will govern these Terms & Conditions and Privacy Policy.

The User hereby irrevocably and unconditionally consents to submit all disputes pertaining to these Terms & Conditions and Privacy Policy to the exclusive jurisdiction of a sole arbitrator appointed as per the Arbitration and Conciliation Act 1996, as amended from time to time. The seat of arbitration shall be Gurugram, Haryana and the language of the proceedings shall be English.

Language

All communications between the User and Xpesa, the Promoter, and/or any other entity shall be communicated in written form via Electronic Mail (E-Mail) and in English language only. Further, all communications between the User and the Customer Support shall also be conducted in English language only.

© Xpesa Limited 2019