Privacy Notice
Uniorbit Technologies Private Limited (“PowerUp”)is committed to protecting your
privacy. This Privacy Notice (“Notice”) describes how PowerUp collects, uses, discloses
and otherwise processes information about you in connection with our business,
including the provision of our websites at https://www.uni.cards/,
https://www.powerup.money/ and any other websites, apps operated by PowerUp
(“Website”), and the PowerUp Services.
By using our Website/app and signing up for the PowerUp Services, you consent to the
processing, storage, usage, and sharing of the data provided by you pursuant to the
terms of this Notice. We encourage you to read this Privacy Notice from time to time and
to keep yourself updated with any changes that we make to this Notice. If you do not
agree with any part of this Notice, please stop using our services immediately.
Where this Privacy Notice refers to “PowerUp”, “we”, “us, “our”, this means one or
more of the particular Group Companies that provide the particular Website, mobile
application, newsletter or PowerUp Services to you, recruits you, uses testimonials from
you, sends marketing communications to you, hosts an event you visit, or organizes a
program in which you participate.
This Notice only applies to the use of your Personal Data by us or on our behalf. It
doesnotapply to Personal Data collected by third parties during your
communications/dealings with those third parties or your use of their products or
services.
1. COLLECTION AND USAGE OF PERSONAL DATA
a) Website and app visitors: If you browse our Website or use our app, we may log
certain information such as your IP address, browser type, mobile operating system,
manufacturer, model of your mobile device, geolocation, preferred language, access
time, and time spent. We will also collect information about the pages you view
within our sites and other actions you take while visiting our Website/app.
b) PowerUp Services: We collect information including name, email ID, phone number,
address, gender, date of birth, username, password, and other registration
information required for provision of the PowerUp Services. We may also collect
transaction level information including details of purchases, loans used, payment
methods, etc., which are related to the PowerUp Services.
c) Third Parties: We collect information required by third parties including lenders,
merchants, SEBI registered intermediaries or such other third parties for providing
their products/ services to you. This information may include your KYC data like
identity proof or address proof, gender, or bank account information. We may also
collect your PAN Card information, Aadhaar Card information, investment
portfolio information, financial information such as employer name, monthly
salary, bank statements, credit information, GST information, and copies of
identification documents which may be required by such third parties for the
onboarding of your application to avail any services.
d) Visitors to our Offices: If you visit our office, we may process Personal Data about
you that you volunteer in connection with your visit and any enquiries you make.
For example, you may volunteer Personal Data when signing in as a guest. CCTV
footage may also be collected for security purposes.
e) Job applicants: If you apply for a job with us, whether through our Website or
otherwise, we will collect, process, and store your Personal Data in connection with
your application.
f) Shareholders: If you are a shareholder of our group companies, we will process your
Personal Data in relation to your investment and for our reporting obligations.
g) Grievance related information on any complaints or queries raised by you to our
support or grievance team.
2. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
We collect and process your Personal Data for the following purposes:
Purpose
Description
Providing PowerUp Services
We process your Personal Data to perform our contract
with you for the provision of PowerUp Services
including:
● Account opening and verification of identity for
various PowerUp products;
● KYC and credit checks;
● Authentication and authorization of transactions;
● Collections or recovery of loan;
● To satisfy our obligations under the applicable terms
of use.
Power Age
We may collect information such as your name,
age,
income bracket, PAN data and investment portfolio to
calculate the age at which you may become
financially free. Such information is collected with your
consent.
Providing and improving our
websites (including our social
media pages)
We process your information to operate and administer
our websites, to provide you with the content you
access and request and to analyze overall trends and
help us improve the user experience on our websites
and our apps.
Promoting the security of our
websites
We process your Personal Data by tracking use of our
websites and verifying and investigating activity.
Displaying personalized
advertisements and content.
We process your Personal Data to conduct market
research, advertise to you, provide personalized
information about us on and off our websites and to
provide other personalized content based upon your
activities and interests while using the PowerUp
Services.
Registering visitors
We may process your Personal Data if you visit our
offices including registration information and
associated information, for security reasons.
Managing event registrations
and attendance
We may process your Personal Data to plan and host
events or webinars for which you have registered or
that you attend including sending related
communications to you provided you have consented
to the same.
Sending communications
Subject to explicit and prior consent from you, we
process your Personal Data to send you marketing
information, product recommendations and other
communications (e.g., marketing newsletters,
telemarketing calls, SMS or push notifications,
information about our products, news, or events) about
us, our products, our Group Companies and partners.
Handling customer and user
support requests
We use the information we collect (including recordings
of customer support calls) to assist you when you
contact our customer support services to investigate
and resolve your queries, monitor, and improve our
customer support responses.
Providing personalized
interactions
We process your Personal Datato customize our
interactions with you.
Managing our customer and
user accounts
We process your information to manage customerand
user accounts for customer correspondence and
customer relationship management.
Preparing internal reports and
business modeling
We may process your information (including usage
data) for internal reporting and business modeling
purposes (e.g., forecasting, revenue, capacity planning,
product strategy).
Managing compensation for
employees
We may process your Personal Data (including your
usage data) for the purposes of determining
compensation for employees including for determining
commissions.
Undertaking financial
reporting
We may process your Personal Data (including your
usage data) for the purposes of financial reporting.
Aggregating data
We may process your Personal Data (including your
usage data) for the purposes of aggregating this
information to ensure that it is no longer identifying
you.
Managing, and participating
in, webinars, contests,
programs, training,
certifications or promotions
We may process your Personal Data upon prior consent
if you are eligible for a webinar, contest, promotion,
training, certification or a program.
In some cases where the training or certification is
through your employer, we will share your Personal
Data with your employer.
Some webinars, contests, programs, trainings,
certifications and promotions have additional rules
containing information about how we will process your
Personal Data.
Managing payments
If you have provided payment information to us, we
process your Personal Data to verify that information
and to collect payments to the extent that doing so is
necessary to complete a transaction and perform our
contract with you.
Administering surveys and
conducting research
We may process your information in order to meet the
goals set out in surveys or research as well as to analyze
our compliance with internal policies and improve our
services.
Complying with legal
obligations
We process your Personal when cooperating with public
and government authorities, courts, or regulators in
accordance with our legal obligations under applicable
laws to the extent this requires the processing or
disclosure of Personal Data to protect our rights.
If we need to collect and process Personal Data by law, or under a contract we have
executed with you and you do not consent to provide the required Personal Data when
requested, we may not be able to perform our contract with you and certain features of
the PowerUp Services may be restricted, unavailable or unusable if you choose not to
provide certain information.
We are committed to keeping all financial information you share, if any, safe at all times
and ensure that such data/information is only transacted over secure sites which are
digitally encrypted and provide a reasonable degree of care available. PowerUp will not
use your financial information, if any, for any purpose other than to provide the
PowerUp Services.
3. WITH WHOM DO WE SHARE PERSONAL DATA?
When processing your Personal Data, we may need to share it with third parties
(including other entities within our Group Companies), as set out below. This list is
non-exhaustive and there may be circumstances where we need to share Personal Data
with other third parties:
● With third party entities providing our customers with service(s) through the
PowerUp app including entities regulated by the Reserve Bank of India (“RBI”) and
Securities Exchange Board of India (“SEBI”) such as Banks, Non-Banking Financial
Companies, Registered Investment Advisors, etc.
● With third party service providers providing us with services such as IT and system
administration and hosting, research and analytics, marketing, events planning,
customer support and data enrichment, fraud prevention, SMS services, credit checks,
collection and recovery of loans, background verification, anti-spamming and
anti-phishing services or for them to reach out to you on our behalf.
● With third party payment processors who may process your payment information for
PowerUp.
● With third-party service providers that are assisting us with the operation and
administration of events and with sponsors of contests for which you register. If we
are running an event in partnership with other organizations, we will share your
Personal Data with such organizations for use in relation to the event.
● With external recruiters, and related organizations such as third-party providers, that
undertake employee background checks on our behalf and on behalf of other entities
within our Group Companies.
● In individual instances, we may share your Personal Data with professional advisers
acting as service providers - including lawyers, bankers, auditors, and insurers who
provide consultancy, banking, legal, insurance and accounting services, and to the
extent we are legally obliged to share your Personal Data.
● Law enforcement or other government and regulatory agencies and bodies or other
third parties as required by, and in accordance with, applicable law or regulation.
● With Group Companies within our corporate group and companies that we acquire in
the future after they are made part of the corporate group, to the extent such sharing
of data is necessary to fulfil a request you have submitted via our websites or for care
and customer support, sourcing, sales management, marketing, technical operations,
account management purposes and other support services.
● If we are involved in a merger, reorganization, or other fundamental corporate change
with a third party or sell/buy a business unit to/from a third party, or if all or a
portion of our business, assets or stock are acquired by a third party, with such third
party including at the due diligence stage.
● With Sub-Processors we use to assist PowerUp in providing our customers with the
PowerUp Service(s). The list of Sub-Processors is given below under Annex-I. This list
may be updated from time to time.
● Other third parties - Occasionally, we may receive requests from third parties with
authority to obtain disclosure of Personal Data, such as to check that we are
complying with applicable law and regulation, to investigate an alleged crime, or to
establish, exercise or defend legal rights. We will only fulfil requests for Personal Data
where we are required to do so in accordance with applicable law or regulation.
Where necessary (such as when we transfer data to service providers/Sub-Processors)
we put in place appropriate contractual arrangements and security mechanisms to
protect the Personal Data shared and to comply with our data protection, confidentiality
and security standards and obligations. Further details can be provided upon request.
4. NON-PERSONALLY IDENTIFIABLE INFORMATION
Non-personally identifiable information is information that does not identify a specific
end user. This type of information may include things like the URL of the website you
visited before coming to our Website, the URL of the website you visit after leaving our
Website, the type of browser you are using and your Internet Protocol address, etc. Such
information may be used by us or our partners to analyse trends and gather
demographic information, etc.
5. COOKIES
We use data collection devices such as “cookies,” etc. on certain parts of the app and
Website to help analyse the PowerUp Services, user interaction with the mobile
application, measure promotional effectiveness, and promote trust and safety. For the
sake of clarity, “cookies” are small files placed on your device hard-drive/storage that
assist us in providing the PowerUp Services.
6. CHILDREN
Our websites and the PowerUp Services are not directed at minors. We do not
knowingly collect Personal Data for children under the age of 18 unless we have
obtained consent from a parent or guardian, or such collection is subject to a separate
agreement with us or the visit by a child is unsolicited or incidental. If you believe we
have mistakenly or unintentionally collected Personal Data of a minor without
appropriate consent, please contact us by using the information in Section 12 below and
we will take steps to delete their Personal Data from our systems.
7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We may retain your Personal Data for a period of time consistent with the original
purpose of collection (see Section 1 above) or as long as required to fulfill our legal or
business obligations or as prescribed by a regulatory body including the Reserve Bank of
India and the Securities and Exchange Board of India. We determine the appropriate
retention period for Personal Data on the basis of the amount, nature, and sensitivity of
the Personal Data being processed, the potential risk of harm from unauthorized use or
disclosure of the Personal Data and on the basis of applicable legal requirements.
After expiry of the applicable retention periods, your Personal Data will be deleted.
Please note that we may retain certain information if necessary for our own legitimate
business interests such as fraud prevention and enhancing users’ safety and security or
to fulfil our legal and contractual obligations and compliance requirements. For more
information on data retention periods, please contact us by using the information in
Section 12 below.
8. YOUR RIGHTS
You may have certain rights relating to your Personal Data. These rights may include the
right to:
● Manage, review, or withdraw your consent;
● Access your Personal Data held by us;
● Know more about how we process your Personal Data;
● Know about the identities of the Data Fiduciaries with whom the Personal Data has
been shared along with the categories of personal data so shared;
● Rectify inaccurate Personal Data and ensure it is updated and complete;
● Erase or delete your Personal Data unless retention is required under applicable
law; and
● Withdraw your consent at any time (to the extent we base processing on consent),
without affecting the lawfulness of the processing based on such consent before its
withdrawal.
To exercise any of the abovementioned rights, you may contact us using the information
in Section 12 below.
9. HOW DOES UNI KEEP PERSONAL DATA SECURE?
We use appropriate technical and organizational measures as per prevalent industry
standards to protect the Personal Data that we collect and process. We have
implemented information security policies, rules and technical measures to protect the
Personal Data under our control from unauthorized access, improper use or disclosure,
unauthorized modification and unlawful destruction or accidental loss. In addition, all
our employees and data processors (i.e., those who process your Personal Data on our
behalf) are obliged to respect the confidentiality of the Personal Data of all users of our
Website and the PowerUp Services. The measures we use are designed to provide a level
of security appropriate to the risk of processing your Personal Data.
While information security risks are always evolving, so are the controls. The controls,
so implemented, are periodically reviewed as part of internal and external audits. If you
have questions about the security of your Personal Data, please contact us using the
details in Section 12.
Note that we are not liable for any third-party breaches to the security of your
information.
All Personal Data collected and processed by us securely reside inside on one or more
data centres located within India. However, there may be instances where certain
non-sensitive customer data collected by us may be stored on servers located outside of
India to the extent it is legally permitted. Please understand that different countries may
have different levels of data protection, and by agreeing to this transfer, you
acknowledge and accept these risks. We take your privacy seriously and ensure that all
data is transferred and handled in compliance with applicable data protection laws.
10. LINKS TO THIRD PARTIES SITES
Our Website or applications may have links to third-party websites/apps. Your use of
these features may result in the collection, processing or sharing of information about
you by such third parties, depending on the feature. We are not aware of the practices of
such third parties and will not be responsible for any processing by such third parties of
your data.
11. CHANGES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time to reflect changes in our practices,
technologies, legal requirements, and other factors. If we do, we will update the
“effective date” at the top. If we make a material update, we may provide you with a
notice such as by posting a notice on our website or apps or by contacting you directly,
or where required under applicable law and feasible, seek your consent to these
changes.
We encourage you to periodically review this Privacy Notice to stay informed about our
collection, processing and sharing of your Personal Data.
12. GRIEVANCES
If you have concerns about any aspect of our privacy practices, including the way we
have handled your Personal Data, please contact us using the detailsbelow:
Grievance Redressal Officer: Danish Mirza
Email Id: gro@uni.club
Phone Number: 080 6821 6821
You may also write to care@uni.club in case of any issues.
13. DEFINITIONS
“Personal Data” means any data about an individual who is identifiable by or in
relation to such data.
“Group Companies” means, with respect to a Uniorbit Technologies Private Limited
entity, any entity that directly or indirectly controls, is controlled by, or is under common
control with such Uni entity, whereby “control” (including, with correlative meaning,
the terms “controlled by” and “under common control”) means the possession, directly
or indirectly, of the power to direct, or cause the direction of the management and
policies of such person, whether through the ownership of voting securities, by contract,
or otherwise.
“PowerUp Services” means digital platforms and technology solutions developed,
owned, and operated by PowerUp or its Group Companies which enable users and
customers to access financial services, products or other investment services offered by
PowerUp or its third-party service providers.
“Sub-Processor” means third-party businesses engaged by PowerUp for performing
Personal Data processing on its behalf.
“Data Fiduciary(ies)” means any person who alone or in conjunction with other persons
determines the purpose and means of processing of personal data.
Annex I- Sub-processor list (subject to updates from time to time)
Vendor Name
Purpose
Razorpay
Payment gateway
Amazon Web Services
Cloud services
Setu
Bank account verification
Cashfree
Payment Gateway
YM
Communications
Moengage
Marketing campaigns
Freshdesk
Care management tool
CRIF
● Communications
● Identity verification including KYC
● DoB confirmation
CIBIL
● Communications
● Identity verification including KYC
● DoB confirmation
Hyperverge
● Communications
● Identity verification including KYC
● DoB confirmation
Gupshup
SMS Service
Karza
Pan and address validation
PayU
Risk underwriting
BureauId
Internet Binding, Phone and Email
Intelligence
Delhivery
● Logistics
● API Intelligence
Mongo DB
Database service provider
Poweredge Analytics and Services
Private Limited
Technology Service Provider
Karix
RCS Messaging
Muvi
Video Streaming
On Grid
Background Verification
