Privacy Policy

1. Tutelar Solutions Private Limited along with its subsidiaries, associated entities and affiliates (“tutelar”, “we”, “our” or “us”) acknowledges the importance of safeguarding information as well as personal details and has hence, formulated this policy (hereinafter referred to as the “Privacy Policy”) with respect to access and usage rights of our website www.tutelar.io , its mobile application or any other platform or medium through which the Services (defined hereinafter) are made available “Website” and other sub - domains, products, services, features, technologies as offered on our Website, or in any other manner (collectively, the “Services”). Tutelar is committed to respecting your privacy and recognizes your need for appropriate protection and management of any Information (as defined below) you share with us.
2. This Privacy Policy describes:
1. how we collect, use, disclose, process, store, and transfer your Information (as defined below);
2. the legal basis for such collection of the Information and your rights thereof;
3. the information that we collect through the Website or otherwise, which is hosted and operated from India;
4. the purpose of collection and use of the Information;
5. the use and role of cookies and similar text files on the Website; and
6. the security measures we have in place to protect the Information, collected online or otherwise;
7. and should be read in conjunction and together with the terms of use available on the Platform (“Terms of Use”). Words and expressions used in this Privacy Policy but not defined herein shall have the meanings ascribed to them in the Terms of Use.
3. This Privacy Policy does not govern any other information or communications that may have been collected through:
1. our websites that do not link to this Privacy Policy;
2. third-party websites to which the Website may link
4. This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder. Further, this Privacy Policy is published and shall be construed in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data of Information) Rules, 2011 which mandates publishing of a privacy policy by an entity which collects, uses, storages and/or transfers sensitive personal data or information. This Privacy Policy is a legally binding document between you and us.
5. Any third parties engaged by us, and who have or may have access to the Information, will be expected to have read, understand and comply with this Privacy Policy.
6. By accessing and/or using our Website or Services and/or providing the Information as described in this Privacy Policy, you consent to the collection, storage, use, disclosure, processing or transfer of such Information in the manner and for the purposes mentioned in this Privacy Policy, including but not limited to your consent for sharing your Information as per this Privacy Policy. You undertake that you have the capacity to enter into a legally binding contract vide this Privacy Policy, which constitutes a legally binding document between you and Tutelar under applicable laws, in particular, the Indian Contract Act, 1872. If you are not comfortable or disagree with any of the terms or policies described in this Privacy Policy, you may choose to discontinue usage of the Website, Services or the Software. Should you disagree with this Privacy Policy and continue to use the Website, Services or the Software and provide your Information, we disclaim any and all liabilities arising therefrom, and it shall be assumed by your continued use of the Website, Services or the Software that you have accepted this Privacy Policy and any other online terms and conditions, including the Terms of Use.
7. If you are or your organization is our client and have entered into a separate agreement with us, such agreement may have privacy terms that would also apply in addition to the Information you provide to us under such agreement. You are requested to review the terms of that agreement, as well.
8. Any third party may either collect your Information or transfer the same to us. The Information provided to us by such third parties is collected by them under their respective privacy policies and therefore, governed by such terms and conditions.
9. Notwithstanding anything contained herein, if you breach any of terms of the Privacy Policy, we reserve the right to take necessary legal or other action against you, including but not limited to, denying or revoking access to the Website, Services or Software.
10. Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on the Website. It is recommended that you regularly check this Privacy Policy to apprise yourself of any updates. Your continued use of Website, Services, or Software thereafter, will imply your unconditional acceptance of any such updates to this Privacy Policy.

1. The term “Information” for the purposes of this Privacy Policy shall mean the following:
1. name, telephone number, date of incorporation, registered address, email id, any other contact information, PAN, company identification number, any other business proof documents or KYC documents as per RBI norms and any other financial information including bank account details, credit / debit card details or such other payment information in a personally identifiable form; and
2. financial information including bank account details, credit / debit card details or such other payment information in a non- personally identifiable form (“Customer Information”).
2. While the Customer Information processed by us shall be in anonymized or non-personally identifiable form, we may specifically process such Customer Information in a personally identifiable form, in the event of: (a) chargebacks; (b) fraudulent transactions; (c) failed transactions; or (d) in furtherance of a notice, order or show cause received from law enforcement agency
3. Tutelar may collect Information from you when you: (i) register on the Website; (ii) update or change personal details in your account; (iii) use the Website and for rendering Services; or (iv) participate in campaigns or respond to questionnaires published by Tutelar on its Website.
4. You hereby acknowledge and agree that all Information is provided by you to Tutelar voluntarily.
5. Information collected by Tutelar from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such Information was collected.

1. We may use the Information we collect to:
1. Provide you with the Services;
2. Facilitate communication and routing payment transactions between different payment service providers;
3. Send updates about our Services, emails, promotional materials and other information that may be of interest to you. You will always have an option to stop getting these updates or unsubscribe from getting any emails or other notifications by updating your settings or by following the procedures we may provide;
4. respond to your questions or comments;
5. send you system notifications such as version updates, warnings or changes in the Privacy Policy; and
6. communicate with you in any other context, including, but not limited to, providing customer support, meeting legal requirements or enforcing compliance with this Privacy Policy or the Terms of Use
2. We may also use Information for the following purposes:
1. to operate and improve the Website to foster a positive user experience and to improve our business as a whole;
2. to analyze data, track trends, build algorithms and create databases for rating systems and recommendation engines and to carry out research activities;
3. to carry out non-targeting activities such as frequency capping, compliance, billing, advertisement reporting or delivery, market research or product development purposes;
4. to conduct audits and quality assessment procedures for the Website;
5. to analyze the use of our resources, troubleshooting problems and improving the Website;
6. to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of the Terms of Use, this Privacy Policy or as otherwise required by law or initiate any legal proceedings against you in relation to the foregoing;
7. to respond to any queries that you may have and to communicate information to you, including notifications of any promotions or alerts and any updates to the Website; and
8. to contact you from time to time to record your feedback on the Website or Services, as they currently stand, and/or other such services that may be offered in the future.
3. We may also generate anonymized and aggregated information from your use of the Website or Services or Software. Anonymized or aggregated information is not Information, since we will not be able to re-identify you using any means available to us from such anonymized or aggregated information. The anonymized and aggregated information is used for a variety of functions, including to help us identify and remediate any bugs, and to improve the performance of our Website, Software and Services. The Company may use such information in a number of ways, including internal analysis, analytics and research, including any research conducted by third parties. We may share this information with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identiWhen you send an email message or otherwise contact Tutelar through its Website, Tutelar may use the Information provided by you to respond to your communication. Tutelar may also archive such Information and/or use it for future communications with you to inform you regarding updates, newsletters, offers, new services and promotions.fying you.
4. When you send an email message or otherwise contact Tutelar through its Website, Tutelar may use the Information provided by you to respond to your communication. Tutelar may also archive such Information and/or use it for future communications with you to inform you regarding updates, newsletters, offers, new services and promotions.

1. By mere use of the Website or availing our Services, you expressly consent to Tutelar’s use, processing, transfer, storage and disclosure of your Information and Third-Party Information (as defined in the Terms of Use) in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use this Website or avail our Services or Software(s), in any manner.
2. In order to avail any Service or use the Website, you may be using Third-Party Information. You hereby agree that you have obtained explicit written authorization and consent from all such subjects/individuals whose information you verify/provide data against in the format required by the applicable laws in force, from time to time and store the same in your custody basis such laws. You hereby represent and warrant that Tutelar shall not be held responsible, liable or accountable in any manner or to any extent whatsoever, for your failure to perform obligations under this Clause.
3. In case you wish to avail any or all of the Services provided by Tutelar on the Website or for using our Software, Tutelar shall provide a username and password to you (“Login Credentials”) as set out in the Terms of Use. You hereby explicitly agree that your use and access of the Login Credentials shall be governed by the Terms of Use read with the terms of this Privacy Policy and any other agreement that you may enter into with Tutelar.

1. Tutelar may maintain your Information in electronic form on its devices and on the equipment of Tutelar’s employees. The Information is made accessible to employees, agents, officers, legal advisors, auditors or partners and third-parties only on a “need-to- know” basis.
2. Tutelar does not rent, sell, or share Information with other people except with your consent, under the following circumstances:
1. Tutelar may engage third party vendors and/or contractors to perform certain support services, who may have access to Information.
2. Tutelar may transfer your Information to its subsidiaries, affiliates, associated and group companies in order for such subsidiaries, affiliates, associated and group companies to efficiently provide certain products and/or services and/or particular features, and for internal corporate/business restructuring purposes and audit related purposes etc. in compliance with applicable laws.
3. Tutelar may transfer your Information with information technology service providers who are engaged in the provision of information technology services for fulfilling various aspects of the Website and for research and analytics.
4. In order to process the transactions, Tutelar may direct you to an authorized payment aggregator / payment gateway / card networks / issuing or acquiring banks/ other banking partners, who may have access to the Information provided by you to give effect to such transactions.
5. Tutelar may transfer Information with government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise legal rights; to defend against legal claims; or as otherwise required by law. This may be done in response to a law enforcement agency's request, or if arising due to a statutory or regulatory compliance requirement.
3. You shall have the right to review your Information collected by us and to modify or delete any such Information, save and except when such Information is requested to be retained by us in accordance with applicable laws. You hereby understand that any such modification or deletion of the Information may affect your ability to use the Website or our Services or Software.

1. We store your Information until it is no longer necessary to provide the Services, or to fulfil the purposes for which it was collected (including for purposes of meeting any legal, administrative, accounting, or other reporting requirements), or until such time as you may request for deletion of your Information. We may also be required to retain certain Information in order to comply with local laws. If you wish to delete your Information, you should submit a delete request to us in accordance with "Contact Us" below or log-in to your account and make a formal request to delete your Information. However, we might retain certain Information in a non- identifiable form indefinitely in accordance with the terms of this Privacy Policy and subject to applicable laws at all times.
2. We may store your Information using our own secure on-site servers or other internally hosted technology. Your Information may also be stored by third parties, via cloud services or other technology, to support our business operations. These third parties do not use or have access to your Information other than for cloud storage and retrieval, and we require such parties to ensure at least the same level of security that we use to protect your Information.

1. Cookies are text files which Tutelar places in your computer's browser to maintain your log-in and session details. Tutelar may use necessary session cookies which enables Tutelar to recognise you and makes it easier for you to return to Website and interact with the Tutelar’s Services, and/or preference cookies (including search and browsing history) which are stored for the maximum duration permitted by law, and/or statistics cookies (including Usage Information such as unique request ID, statistical data) which are stored for the maximum duration permitted by law (collectively referred to as the “Cookies”).
2. Cookies, by themselves, do not communicate to Tutelar, unless you provide your e-mail address or other personal Information to Tutelar. For example, you availing Services provided by Tutelar. Cookies are designed to hold a marginal amount of data specific to a particular user and website and can be accessed either by the web server or the user device.
3. However, once you choose to furnish the Website with personal Information, this information may be linked to the data stored in the Cookie. Tutelar uses Cookies to understand Website usage and to improve the content and offerings on the Website. For example, Tutelar may use Cookies to personalize your experience on the Website. Tutelar also may use Cookies to offer you products, programs, or Services. Cookies may be placed on the Website by third-parties as well, the use of which Tutelar does not control.
4. Cookies are retained in your browser unless specifically deleted, depending on the type of Cookies. If you decline the Cookies, you may be unable to use certain features on the Website. By using or accessing the Website and/or the Services, you hereby explicitly authorise Tutelar and give your consent to Tutelar to store, use and access Cookies for the purposes outlined in this Privacy Policy. Most browsers allow you to control Cookies through their settings, which may be adapted to reflect your consent to the use of Cookies, and they may also enable you to review and erase Cookies.

1. Tutelar may engage third party vendors and/or contractors to perform certain support services for Tutelar, including, without limitation, software maintenance services and marketing services, web hosting services, and any such other related services which are required by Tutelar to provide its Services, efficiently. These third parties may have limited access to the Information. If they do, this limited access is provided so that they may perform these tasks for Tutelar and they are not authorized by Tutelar to otherwise use or disclose Information, except to the extent required by law. Tutelar does not make any representations concerning the privacy practices or policies or terms of use of such websites, nor does it control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Tutelar of the website, the website's provider, or the information on such website.
2. The Website may contain links and interactive functionality interacting with the websites of third parties. Tutelar is not responsible for and has no liability for the functionality, actions, inactions, privacy settings, privacy policies, terms, or content of any such website. Before enabling any sharing functions to communicate with any such website or otherwise visiting any such website, Tutelar strongly recommends that you review and understand the terms and conditions, privacy policies, settings, and information-sharing functions of each such third-party website.

• Tutelar may disclose and/or transfer Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Tutelar.

• You have the right to withdraw your consent at any point, provided such withdrawal of the consent is intimated to Tutelar in writing through an email at https://www.tutelar.io requesting the same.
• Once you withdraw your consent to share the Information collected by Tutelar, Tutelar shall have the option not to fulfil the purposes for which the said Information was sought and Tutelar may restrict you from using the Services, Software, and/or the Website itself.

• Tutelar shall store your Information at least for such period as may be required and permitted by law. These periods vary depending on the nature of the Information and your interactions with Tutelar. Such Information collected by Tutelar shall only be stored in servers located in India, while ensuring compliance with statutory obligations/ regulatory instructions and requirements. We do not transfer any Information outside India. However, in case of transfer of data to any other country, legal protections applicable to Information in the concerned country will apply.
• You agree that you will not submit any false Information or any illegal or damaging content to the Website or while using the Services or Software. Tutelar reserves the right to terminate access to or the ability to interact with the Website, or the Services or Software, in response to any concerns Tutelar may have about false, illegal, or damaging content, or for any other reason, in its absolute and sole discretion.

• Tutelar has taken adequate measures to protect the security of Information and to ensure that your choices for its intended use are honoured. Tutelar takes robust precautions to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your Information, we cannot guarantee its security and it may also be important to understand that no method of transmission over the internet, or method of electronic storage, is completely secure.
• Tutelar considers the confidentiality and security of your Information to be of utmost importance. Tutelar, therefore uses industry standards, and physical, technical and administrative security measures to keep Information confidential and secure and will not share your Information with third parties, except as otherwise provided in this Privacy Policy or Terms of Use, or any agreement entered between Tutelar and you.
• Access to your online account on the Website is via. Login Credentials, which is password protected and this helps to secure your account information. You are solely responsible for maintaining the security and confidentiality of your account, including passwords and the Login Credentials. To ensure safety of your personal Information, you are advised against sharing your Login Credentials with anyone. If you suspect any unauthorized use of your account, you must immediately notify Tutelar by sending an email to info@tutelar.io.
• For any loss or theft of Information, due to unauthorized access to your device through which you use the Website or other reasons solely attributable to you, Tutelar shall not be held liable or responsible under any circumstance whatsoever. Further, Tutelar shall not be responsible for any breach of security, or for any actions of any third parties, or for Force Majeure Event (as defined in the Terms of Use).
• Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us that they apply security measures that they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Information, by these service providers.

• Tutelar does not intend to attract children under 13 years of age to enter into binding legal contracts under the laws of their respective jurisdictions. We do not knowingly collect or solicit personal Information from children under 13 years of age or knowingly allow such persons to register for the Services. If you are under 13 years of age, please do not attempt to register for the Services or send any Information about yourself to us, including your name, address, telephone number, or email address. If we learn that we have collected personal Information from a child under 13 years of age without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any Information from or about a child under 13 years of age, please contact us at info@tutelar.io.

• You hereby agree and confirm that Tutelar shall not store or retain any Information belonging to any data subject at any time, save and except as provided in this Privacy Policy. Accordingly, Tutelar shall not in any manner be held or be responsible or liable, for any and all unforeseen contingency, claims, liabilities, demands, losses, damages or expenses, arising due to absence of storage or retention of any such Information which shall be your sole liability, and in no event shall Tutelar be required to be present or produce any record of such Information. It shall be your sole responsibility to ensure that you obtain the explicit written authorisation from the data subjects (whose Information is passed through the Tutelar Services or Software) as required by law and/or any contract to access, collect, store and transmit personal data of such subjects using the Services of Tutelar.

• You have the option to 'opt-out' of all Tutelar’s newsletters and other general email marketing communications by way of links provided at the bottom of each mailer. Tutelar respects your privacy and in the event that you choose not to receive such mailers, it shall take all adequate steps to remove you from such lists.

• Notwithstanding anything to the contrary contained in this Privacy Policy and/or the Terms of Use, in case of any conflict between any terms of this Privacy Policy and/or the Terms of Use and/or and any other agreement that you may enter into with Tutelar for availing the Services, the terms of the agreement executed with Tutelar for availing the Services shall prevail at all times.

If you wish to make a complaint regarding any violation of the provisions of this Privacy Policy, you may send a written complaint to the grievance officer, who shall address the complaint in accordance with the provisions of the Information Technology Act, 2000 and rules made thereunder. The name and contact details of the grievance officer are provided below:

If you have questions or concerns about this Privacy Policy, please contact Tutelar at https://www.tutelar.io.