Privacy Statement
Last updated: July 31, 2020A. General Information
When does this Privacy Statement apply?
This Privacy Statement applies to information that can be used to identify you (“Personal Data”) and that you provide to Wisely through wisely.tanla.com or which is derived from the Personal Data as outlined below.
Who is the Data Controller?
The data controller of wisely.tanla.com is Tanla Digital Labs Private Limited, Hitech City Road, Madhapur, Hyderabad, India (“Wisely”). Wiseley’s’ data protection officer can be reached at privacy@tanla.com.
What Personal Data Does Wisely collect?
Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites and Services will be apparent from the context in which you provide the data. In particular:
- When you register for a Wisely account we collect your full name, email address, KYC Documentation, and account log-in credentials. We may require you to provide us with additional Personal Data as you use our Services.
- Transaction and experience information – When you use our Services or access our Sites, for example, to add your partner or to send any messages to your customers, we collect information about the transaction, as well as other information associated with the transaction such as volumes, sender IDs, Sub-account details, Device Information, Technical Usage Data, and Geolocation Information.
- Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.
Why Do We Retain Personal Data?
We retain Personal Data to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Statement.
How We Use Personal Data
We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete communication transactions and to provide communication-related services to our Users.
We may send you email marketing communications about Wisely products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. For example, when we collect your business contact details, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns
When you visit our Sites, we (and our service providers) may use Personal Data collected from you and your device to target advertisements for Wisely Services to you on our Sites and other sites you visit (“interest-based advertising”), where allowed by applicable law. For example, when you visit our Site, we will use cookies to identify your device and direct ads for our Services to you. You have choices and control over our cookies (or similar technologies) we use to advertise to you.
We do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers, or our Site visitors.
How We disclose Personal Data
Wisely does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.
Tanla. We share Personal Data with other Tanla entities in order to provide our Services and for internal administration purposes.
Service providers. We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf.
Business partners. We share Personal Data with third party business partners when this is necessary to provide our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are Aggregators and Telecom Service providers.
Compliance and harm prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Wisely, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
Your Rights and Choices
You have choices regarding our use and disclosure of your Personal Data:
Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages and notifications that are required to provide you with our Services.
Your data protection rights. Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:
- The right to request confirmation of whether Wisely processes Personal Data relating to you, and if so, to request a copy of that Personal Data which is provided while registering on the portal;
- The right to request that Wisely rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
- The right to request that Wisely erase your Personal Data in certain circumstances provided by law and by deactivating your subscription to the services.
Where the processing of your Personal Data is based on your previously given consent while signing up in the portal, you have the right to withdraw your consent at any time by deactivating the account by providing a written request.
Security and Retention.
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
Use by Minors.
The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services.
Updates To this Privacy Policy and Notifications.
We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services.
To submit a request to exercise any of the rights described above, you may contact Tanla at privacy@tanla.com. We may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required.
Contact Us
If You have any questions or complaints about this Privacy Policy, please contact us electronically or send physical mail to:
Tanla Digital Labs Private Limited
Hi-Tech City Road,
Madhapur, Hyderabad 500081
Attention: Wisely Legal