This Privacy Policy & Storage Guidelines document explains TiYa Software Private Limited’s (hereinafter called “Famigo” which expression shall also include affiliated entities, subsidiaries, our authorized representatives or agents and its affiliates) Privacy Policy & Storage Guidelines for data pertaining to Users of Famigo Website or Famigo App.

Famigo.ai:

This website www.famigo.ai (“Website”) is owned and operated by TiYa Software Private Limited (“Tiya Software” which expression shall mean and include its affiliates, successors and permitted assigns), operating under the brand name Famigo. Famigo provides services to the Users through the Website and other related links and is committed to protecting and respecting the privacy of its Users

Famigo: Expense Tracker & Management

Famigo: Expense Tracker & Management” App is owned and operated by “TiYa Software Private Limited, operating under the brand name Famigo. Famigo provides services to the Users through the App published on the Google Play Store and is committed to protecting and respecting the privacy of its Users. In the course of using Website or App or availing the products and services, Famigo may become privy to the personal information of its Users, including information that is of a sensitive/confidential nature. Famigo is strongly committed to protecting the privacy of all stakeholders and all stakeholder data and has necessary and reasonable measures in place to protect the confidentiality of all such information. By using the Website or App Users are accepting the practices described here as part of the Privacy Policy and Storage Guidelines

This Privacy Policy explains our policy regarding the collection, use, disclosure and transfer of your information by Tiya Software Private Limited. and/or its subsidiary(ies) and/or affiliate(s) (collectively referred to as the Company), which operates the website (“Famigo.ai”), mobile applications (Famigo App) and other services including but not limited to delivery of spend analytics based on SMS, Bill Splitting, Money Lending, and related content via the site and application, any mobile or internet connected device or otherwise (collectively the “Famigo App” or “Famigo App Services”). This Privacy Policy forms part and parcel of the Terms of Use of the Famigo App

Collection of Information

Famigo Site/Website: https://famigo.ai

During the use of the Website, Famigo may collect and process such information from the Users, including but not limited to the below mentioned:

Information that the Users provide to Famigo by filling in forms on the Website. This includes contact information such as name, email address, mailing address, phone number, financial information, if any, unique identifiers such as user name, account number, password and preferences information such as favourites lists and transaction history and any Information provided by the User at the time of registration for the product/service offered by Famigo.

Information that the Users provide when the Users write directly to Famigo (including by way of e-mail) or other electronic communication.

Information that the Users provide to Famigo over telephone. Famigo may make and keep a record of the information shared by the Users with Famigo;

Information that the Users provide to Famigo by completing surveys;

Information relating to logs is automatically reported by the User’s browser each time the User accesses a web page. When the User uses the Website, Famigo’s servers automatically record certain information that the User’s web browser sends whenever the User visits any website. These server logs may include information such as the User’s web request, Internet Protocol (IP) address, browser type, referring/ exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information. Famigo uses this information, which does not identify Users, to analyse trends, to administer the Website, to track Users’ movements around the Website and to gather demographic information about the User base as a whole. Famigo does not link this automatically-collected data to personally identifiable information.

Information which is in the nature of personal / sensitive personal information of the User provided to Famigo

Information which may be collected from the authorized representatives, agents, group companies of Famigo from user’s browser, mobile application/devices

This policy is applicable to all information collected from the Users of Famigo including but not limited to the above mentioned information

Famigo App

The information about the User as collected by the app falls under (a) information supplied by users and (b) information automatically tracked while using a mobile device having Famigo App Services enabled (collectively referred to as “information” or “Information”).

Information supplied by Users:

To avail certain services on the Famigo App, users are required to provide some personally identifiable information for the registration process which may include a) your name, b) email address, c) phone number, d) access to your phone’s SMS inbox records d) debit card, credit card, bank details, e) KYC details f) PAN g) residential address etc. and any other such information as required. The Information as supplied by the users enables us to improve Famigo App Services and provide 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 Famigo App Services and for developing new services

Famigo App takes limited access (usually one-time or as provided by the User) to services like Camera, and Microphone, for specific use cases in the app like uploading of bills, on-boarding or KYC requirements. Such access is only taken with the explicit consent of the User, and the specific use of the data is clearly communicated to the User. Location data taken for on-boarding or KYC is taken for limited period, however the User may explicitly provide Location data for longer periods for specific use cases like Expense Tracking and categorization, which is explicitly communicated to the User.

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 the User chooses to decline to submit personally identifiable information on the Famigo App/Site, Famigo may not be able to provide certain services on the App/Site to the User. Famigo will make reasonable efforts to notify the User of the same at the appropriate time. In any case, Famigo will not be liable and or responsible for the denial of certain services to the User or lack of providing the necessary personal information

Information tracked with consent and information automatically tracked while using app:

SMS Inbox Information: The Famigo App also 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 Famigo App accesses business messages that originate from alphanumeric senders. No personal SMSes or OTPs are backed up. Any SMSes reported by users are also used to train our Spam filter algorithm. Users can automatically delete OTPs with a setting to delete OTPs older than 24 hrs in the app

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

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

Google Analytics specifically has been enabled to support display advertising to help us gain an understanding of our users’ Demographics and Interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings options provided by Google

By using the platforms of the Company and/or by providing the above information to Famigo, the user consents to the collection, sharing, disclosure and usage of the information by the Company in accordance with this Privacy policy, other than for specific information that is collected and used based on user’s explicit consent as outlined in this privacy policy

Famigo Stakeholders including Employees, Contractors and Suppliers may also provide personal information through various channels including but not limited to documentation, communication, electronic communication, contracts, agreements, and use of Famigo products and Services. This policy is applicable to all such information collected by Famigo

Data Retention

All User information will be retained for as long as the User account is active or as needed to provide services to the User, and Famigo may retain User information for a longer period unless specifically requested by the user to delete the information as detailed below. This also enables returning users to take advantage of backup of data and restore features where applicable

If the User wishes to cancel its account or requests that Famigo no longer uses its information to provide services, the User may contact Famigo at ask@tiya.ai. Famigo will retain and use User information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements or for other business purposes

Foreign Jurisdiction

Famigo makes no representation that the content contained on the Website is appropriate or to be used or accessed outside of the Republic of India. If the Users use or access the Website from outside the Republic of India, they do so at their own risk and are responsible for compliance with the laws of such jurisdiction

Governing Law

This Policy shall be governed by and construed in accordance with the laws of the Republic of India and subject to the provisions of arbitration set out herein, the courts at Bangalore shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Policy

If any dispute arises between Famigo and the User in connection with or arising out of the validity, interpretation, implementation or alleged breach of any provision of the Policy, such dispute shall be referred to and finally resolved by arbitration in accordance with the Indian Arbitration and Conciliation Act, 1996 for the time being in force, which rules are deemed to be incorporated by reference in this clause.

There shall be one (1) arbitrator and the seat of the arbitration shall be Bangalore, India. The language of the arbitration proceedings and of all written decisions and correspondence relating to the arbitration shall be English.

The Ministry of Electronics and Information Technology (MeitY) operates as the nodal agency for information technology in India.

No Waiver

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

Non-Disclosure of Information

Famigo pledges that it shall not sell or rent Users’ or stakeholders’ personal information to anyone. Famigo will protect every bit of the Users’ business or personal information and maintain the confidentiality of the same. With this seal of trust, Famigo makes its services available to the Users for assessment and analysis that include spend analysis, money management, credit and behaviour scoring, market and product analysis.

Famigo may share your personal information with its group companies in relation to offering of products and services to the User, or for the purposes of the engagement with its stakeholders. Otherwise, Famigo guarantees that it is going to keep all information confidential except in the following cases:

Famigo may disclose Users’ information to governmental and other statutory bodies who have appropriate authorisation to access the same for any specific legal purposes.

Famigo may disclose Users’ information if it is under a duty to do so in order to comply with any legal obligation, or in order to enforce or apply the Terms of Use (displayed on the Website), or to protect the rights, property or safety of Famigo, its Users or others. This includes exchanging information with other companies / agencies that work for fraud prevention and credit reference.

Famigo may disclose Users’ information to its agents under a strict code of confidentiality, where such sharing is required or permitted as per statutory or regulatory requirements.

Famigo may disclose Users’ information to such third parties to whom it transfers its rights and duties under the customer agreement entered into with the Users, where such sharing is required or permitted as per statutory or regulatory requirements. In such an event, the said third parties’ use of the information will be subject to such confidentiality obligations as contained in this Policy.

Famigo may disclose Users’ information to any member of its related or group companies including its subsidiaries, its ultimate holding company and its subsidiaries, as the case may be.

In the event that Famigo sells or buys any business or assets, it may disclose the Users’ information to the prospective seller or buyer of such business or assets. User, email and visitor information is generally one of the transferred business assets in these types of transactions. Famigo may also transfer or assign such information in the course of corporate divestitures, mergers or dissolution.

Famigo shall ensure that in case of disclosure of whole or part of the User’s information to a service provider or agent, within or outside India, the same shall be bound by obligations of confidentiality at least as strict as Famigo’s obligations under this Privacy Policy and the information shall be accorded the same level of protection as provided by Famigo under the terms of this Privacy Policy. Famigo may store the User’s information in locations outside the direct control of Famigo (for instance, on servers or databases co-located with hosting providers).

Opting out or editing customer information

When Users use the Website or Famigo App, we make efforts in good faith to provide Users, as and when requested by Users, with access to their respective 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, 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 Users 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.

To opt out of email correspondence from Famigo or make a change to (or delete) the User information stored in Famigo’s records, Users may write to us and Famigo will respond to the User’s request within 30 days.

Referrals

If the User wishes to introduce Famigo Website or Famigo App to any other person/entity, the User will be asked to provide such person/entity’s name and email address or any other contact details. Famigo will automatically send such person/entity an email or invite in any other form inviting the other entity to visit the Website or App or other Famigo Product offering as applicable. Famigo stores this information for the purpose of sending this invite and keeping a record of the number of persons/entities so referred by the Users. Famigo may send additional emails or information to the said person/entity in connection with services offered by Famigo. Such person/entity may contact Famigo at ask@Famigo.co.in to request that this information be removed from Famigo’s database.

Security and storage of Information

Famigo takes the security of its User’s and Stakeholders’ information very seriously. Famigo protects the User’s information at rest and in flight using bank-level data security: atleast 128 bit-encryption where ever required and Transport Layer Security (SSL where applicable). This creates an encrypted connection between the User’s browser or App and Famigo’s servers. All information remains encrypted at all times. If the User allows Famigo to see its banking information online rather than in paper form, the information is processed by the BOT and not Famigo employees. Also, it is on a read-only basis. Famigo does not have access to change, edit, or modify bank account information in any manner whatsoever. Famigo employees cannot view the User’s banking username and passwords, and the same is securely stored in separate encrypted areas with its financial services providers. All information gathered and provided to Famigo on the Website and Famigo App is encrypted and securely stored within the controlled databases on its secure servers within India. Access to the servers is password-protected and is strictly limited.

If enabled from the app, we take a backup of User’s data on the Famigo App on our Cloud database. This is done for the purpose of enabling users to get their data back in case their phone’s data becomes unusable, if the phone is lost, or the user moves to a new phone device.

We also use this backup to provide useful insights and information related to their spends such as weekly spends in a month, insights related to spend behaviour, etc., and to provide information related to user spends, patterns and user data in the form of aggregated and anonymised statistics on data such as user spends by category, date, time, bank balances, etc.

Famigo does not collect or store any biometric data in our systems or servers, and all limited and specific use of biometric data in any Famigo product is as per regulations and extant statutory guidelines only.

Famigo uses commercially reasonable safeguards to preserve the integrity and security of the Users’ information against loss, theft, unauthorised access, disclosure, reproduction, use or amendment.

The information that is collected from the Users may be transferred to, and stored at, a destination inside India. By submitting information on the Website, the Users agree to this transfer, storing and/ or processing. Famigo will take such steps as it considers reasonably necessary to ensure that the Users’ information is treated securely and in accordance with the Policy.

In using the Website or App, the Users accept the inherent security implications of data transmission over the internet. Therefore, the use of the App or Website will be at the own risk of the users.

Famigo assumes no liability for any disclosure of information due to errors in transmission, unauthorised third party access or other acts of third parties, or acts or omissions beyond its reasonable control and the User agrees not to hold Famigo responsible for any breach of security unless such breach has been caused as a direct result of gross negligence or wilful default by Famigo.

In the event Famigo becomes aware of any breach of the security of the Users’ information, it will promptly notify the users and take appropriate action to the best of its ability to remedy such a breach.

Severability

Famigo has made every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy.

Social Media Widgets

The Website includes Social Media Features, such as the Facebook “Like” button and Widgets, or interactive mini-programs that run on the Website. These features may collect the Users’ IP address, which page the Users are visiting on the Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Website. The Users’ interactions with these features are governed by the privacy policy of the company providing it.

Usage of Information

Access to personal information is strictly restricted and shared in accordance with certain specific internal procedures and safeguards that govern access. Certain features of the Website or App may be available for use without any need to provide details. Other features of the Website may require Users to provide details including but not limited to the User’s name, address, mobile number, email address, PAN No., employment & income details.

Famigo never will sell or rent personal information of its Users and stakeholders to anyone, at any time, for any reason. Famigo may use the User’s personal information in the following ways, viz:

Monitor, improve and administer the Website and improve the quality of services;

Analyse how the Website or App is used, diagnose service or technical problems, and maintain security;

Remember information to help the User effectively access the Website or App;

Monitor aggregate metrics such as total number of views, visitors, traffic and demographic patterns;

To confirm the User’s identity in order to determine its eligibility to use the Website or App and avail of the services;

To notify the User about changes to the Website or App;

To enable Famigo to comply with its legal and regulatory obligations;

To help the User apply for certain products and services.

For the purpose of sending administrative notices, service related alerts and other similar communication with a view to optimising the efficiency of the Website or App.

Doing market research, troubleshooting, protection against error, project planning, fraud and other criminal activity.

To reinforce Famigo’s Terms of Use.

For establishing Identification and to fulfil other KYC requirements before beginning the account based transaction

To provide users with the right kind of products and services

To fulfil our internal checks and other risk parameters of the Company.

To safeguard the interest of the Business and to ensure compliance with laws including credit reporting.

To maintain effective communication on the service availed by the Customer including but not limited to the transaction information, updates/changes to the product, assistance for the Customers etc.

For marketing purpose, especially to promote the services of the Company and to notify about the new product/service offerings for the Customer. We may also use the user’s phone number, email address or other personally identifiable information to send commercial or marketing messages without the user’s consent [with an option to subscribe/unsubscribe (where feasible)]. We may, however, use the user’s email address and phone number without further consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about updates to Famigo App Services, billing, etc.).

We may contact the Users from time to time about updation of personal information to provide such features that we believe may benefit/interest the users.

Famigo 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 our app/site or to our partners.

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 unless as required to fulfil Famigo’s legal and regulatory obligations.

Change of Privacy Policy

In the event Famigo, the same will be updated on the Website. In case of any material changes to the Policy, the Users will be notified by email (sent to the email address specified in the User’s account) or by means of a notice on this Website prior to the change becoming effective. The Users are encouraged to periodically review this page for the latest information on its privacy practices.

Contact and Grievances redressal

Any grievance pertaining to IT and Data Security, and any query related to the Grievance Redressal Policy can be addressed to: ask@tiya.ai