This Privacy Policy explains our policy regarding the collection, use, disclosure and transfer of your information by Twid Rewards Global Private Limited and/or its subsidiary(ies) and/or affiliate(s) (collectively referred to as the "Company"), which operates the website (twidpay.com, hereinafter the "Site"), mobile applications (hereinafter the "Twid App" or "App"), merchant checkout integrations (including SDKs and APIs), and other related services (collectively referred to as the "Twid Platform" or "Platform"). The Platform enables services including but not limited to earning, managing, and redeeming reward points across participating merchants, loyalty program partners, banks, and card issuers — whether through the Twid App, the Site, merchant checkout integrations, or point-of-sale systems.

This Privacy Policy forms part and parcel of the Terms of Use for the Twid Platform. Capitalized terms which have been used here but are undefined shall have the same meaning as attributed to them in the Terms of Use.

As we launch, update, improve and expand the Twid Platform, this policy may change, so please refer to it periodically. By accessing any part of the Twid Platform — including the Twid App, the Site, or merchant checkout integrations — you consent to collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the services that we offer.

The Company respects the privacy of the users of the Twid Platform and is committed to reasonably protect it in all respects. The information about the user as collected by the Company is: (a) information supplied by users, (b) information automatically tracked while using the Twid Platform, including through merchant integrations and partner systems, and (c) in the case of the Twid App specifically, financial transaction data read from alphanumeric sender IDs on SMS (collectively referred to as "Information").

CONSENT AND AUTHORIZATION

By choosing to continue and providing your consent, you authorize Twid to receive your mobile number and transaction information from you and/or the participating merchant, authenticate your identity where required, and communicate with participating banks, card issuers and loyalty program partners to determine your eligibility and fetch your available reward balances. Where you expressly choose to redeem your rewards during checkout, you further authorize Twid to facilitate such redemption and process the transaction. You also consent to Twid processing your personal data and transaction information to provide and improve its services, personalize your experience, prevent fraud, comply with applicable legal and regulatory requirements, and generate analytics and insights in accordance with applicable law and Twid's Privacy Policy.

INFORMATION SUPPLIED BY USERS

To avail certain services on the Twid Platform, users are required to provide some personally identifiable information which may include: a) your name, b) email address, c) phone number, d) debit card, credit card, bank details, e) location, and any other such information as required. Additionally, when using the Twid App specifically, users may be asked to grant access to their phone's SMS inbox records to enable automatic reward point tracking. The Information as supplied by the users enables us to improve the Twid Platform and provide you the most user-friendly experience. All required information is service dependent and the Company may use the above said user Information to maintain, protect, and improve the Twid Platform.

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

In case you choose to decline to submit personally identifiable information on the Twid Platform, we may not be able to provide certain services to you. We will make reasonable efforts to notify you of the same at the appropriate time. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information. When you register with the Twid Platform, we may contact you from time to time about updation of your personal information to provide such features that we believe may benefit/interest you.

INFORMATION AUTOMATICALLY TRACKED WHILE USING THE PLATFORM

SMS Inbox Information (Twid App only): The Twid App collects partial payment data and other information arising out of transactions made from cards, banks or while using other services through SMSes, after obtaining the User's specific consent to allow the App to access the User's SMS inbox.

The Twid App accesses financial transactional messages that originate from alphanumeric senders for automatic addition of reward points basis their transaction in participating merchants. We DO NOT read any personal SMSes or OTPs. Any SMSes reported by users through App customer support are also used to train our Spam filter algorithm.

The collection of such information is only limited to the extent that such data is available in the relevant messages. Twid may also record the identity of the product or service and the price or fee paid or payable in respect thereof in order to auto-reward points to the user.

Merchant Checkout and SDK Information: When you use Twid through a participating merchant's checkout (via SDK or API integration), Twid may collect transaction details, reward redemption selections, device identifiers, and session data necessary to process your payment and provide the service.

Demographic and Related Information: We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track user behaviour on our website and app.

Google Analytics specifically has been enabled to support user behaviour, drop off screens etc. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us.

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

LINKS TO THIRD PARTY SITES / AD-SERVERS

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

INFORMATION SHARING

No personally identifiable data of an individual user such as name, phone number, email address, spends data, card details etc. would be shared with any other User and/or third party – unless explicitly approved by the concerned individual user in order to avail of certain services. However, if this conflicts with conditions mentioned in the immediate point above, this condition would become null and void.

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

ACCESSING AND UPDATING PERSONAL INFORMATION

When you use the Twid Platform, we make efforts in good faith to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes.

We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.

In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

INFORMATION STORAGE AND BACKUP

We may take backup of your data on the Twid Platform on our Cloud database. This is done to ensure service continuity, enable data recovery, and allow users to restore their data in case of device loss, data corruption, or migration to a new device.

INFORMATION SECURITY

We take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorised access to systems where we store personal data. All information gathered across the Twid Platform is securely stored within controlled databases. Access to the servers is password-protected and is strictly limited.

UPDATES / CHANGES

We may alter our privacy policy from time to time to incorporate necessary changes in technology, applicable laws or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Privacy Policy or the Terms of Use. Any changes we make will be effective immediately on notice, which we may give by posting the new policy on the Site.

Your continued use of the Twid Platform after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform you via electronic mail. In any case, you are advised to review this Privacy Policy periodically on the Site to ensure that you are aware of the latest version.

QUESTIONS / GRIEVANCE REDRESSAL

In the event you have any grievance relating to the processing of information provided by you, you may contact our Grievance Department, at [email protected] or write to us at the following address:
Twid Rewards Global Private Limited.,
415, 4th Floor, 1st Block,
2nd Main, RT Nagar,
Bangalore - 560032