LAST UPDATED ON: 18.10.2022
This privacy policy (“Policy”) describes how Cymbient Technology Pvt. Ltd. (trade name “Rooba.Finance”) (“Company”,
“we”, “our”, or “us”) collects, uses, shares, and stores personal information of users of its websites, www.rooba.finance and stage.rooba.finance. This Policy applies to the sites, applications, products and services (collectively, “Services”) on or in which it is
posted, linked, or referenced. This Policy also describes other important topics relating to your privacy.If you are a
user in the UK or the European Economic Area (“EEA”), please refer to our section 'Users in UK and EEA' which provides
information on the rights that you have specifically under the General Data Protection Regulation and the UK's Data
Protection Act 2018 (collectively we call them the 'European Data Protection Laws').
Consent
By using the Services, or by otherwise choosing to submit personal information to Rooba and its affiliates, for users
outside of India, except for residents of the United States of America, you consent to the collection, use and
disclosure of your information as outlined in this Policy. If you are a user in the UK or EEA, please refer to our
section Users in UK and EEA, which provides information on the basis on which we and our affiliates may process your
personal information. At any time, you have the right to withdraw your consent to the collection, and future use and
disclosure of your information, subject to reasonable notice and legal, contractual, and technological limitations. You
may make this request by writing to the e-mail address set out below.
Changes to this Privacy Policy
This Privacy Policy is subject to change at any time. We encourage you to periodically review this page for the latest
information on our privacy practices. If we make any changes, we will change the last updated date above.Any
modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of
the changes to the sites (or as otherwise indicated at the time of posting). In all cases, your continued use of the
sites or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the
modified Privacy Policy.
What we and our affiliates Collect
We and our affiliates get information about you in a range of ways.
Information You Give Us.
Information we and our affiliates collect from you may include:
Account Data
- Identity information, such as your first name, last name, username or similar identifier, title, date of birth and
gender;.
- Contact information, such as your postal address, email address and telephone number;
- Profile information, such as your username and password, interests, preferences, feedback and survey responses;
- Usage information, such as information about how you use the Service and interact with us;
- Marketing information, such as your preferences for receiving marketing communications and details about how you engage
with them;
Information we and our affiliates collect automatically
When you use the Platform, our servers automatically record information using cookies and other tracking technologies,
including information that your browser sends whenever you visit the Platform or your mobile application sends when
you're using it. This log data may include your Internet Protocol address, the address of the web page you visited
before coming to the Platform, your browser type and settings, the date and time of your request, information about your
browser configuration and plug-ins, language preferences, and cookie data. Such log data is not routinely deleted. Your
browser gives you the ability to reject cookies. However, setting your browser or device to reject cookies generally
hinders performance and may adversely affect your experience while using the Services.
In addition to log data, we and our affiliates may also collect information about the device you use for the Platform,
including what type of device it is, what operating system you're using, device settings, unique device identifiers, and
crash data. Whether we and our affiliates collect some or all of this information may depend on what type of device
you're using and its settings.
We and our affiliates may combine this information with other information that we and our affiliates have collected
about you, including, where applicable, your name, user name, email address, and other personal information.
Geolocation If you have provided permission through your mobile device and allied mobile applications to allow us to
collect location information through a mobile application, we and our affiliates may obtain your physical location
information in terms of latitude and longitude from technologies like GPS, Wi-Fi, or cell tower proximity. You are able
to withdraw your permission for us to acquire such physical location information from your mobile device through your
mobile device settings, although we and our affiliates do not control this process. If you have questions about how to
disable your mobile device's location services, we recommend you contact your mobile device service provider or the
mobile device manufacturer.
Use of Personal Information
To provide our service
we and our affiliates will use your personal information in the following ways:
- To create your account and associated identity to enable you to access the Services;
- To provide and deliver products and services that you may request.
- To process and complete transactions, and send you related information, including purchase confirmations and invoices.
- To send information, including confirmations, technical notices, updates, security alerts, and support and
administrative messages.
- Conduct audits to verify that our internal processes function as intended and to address legal, regulatory, or
contractual requirements.
- To create your Rooba Wallet to enable you to access the Services.
To comply with law
We and our affiliates use your personal information as we believe necessary or appropriate to comply with applicable
laws (including anti-money laundering (AML) laws, know-your-business (KYB) requirements and know-your-customer (KYC)
requirements), lawful requests and legal process, such as to respond to subpoenas or requests from government
authorities.
To communicate with you
We and our affiliates use your personal information to communicate about promotions, upcoming events, and other news
about products and services offered by us and our selected partners.
To optimize our platform
In order to optimize your user experience, we and our affiliates may use your personal information to operate, maintain,
and improve our Services. We and our affiliates may also use your information to respond to your comments and questions
regarding the Services, and to provide you and other users with general customer service
With your consent
We and our affiliates may use or share your personal information with your consent, such as when you consent to let us
post your testimonials or endorsements on our sites, you instruct us to take a specific action with respect to your
personal information, or you opt into third party marketing communications.
For compliance, fraud prevention, and safety
We and our affiliates may use your personal information to protect, investigate, and deter against fraudulent,
unauthorised, or illegal activity.
Sharing of Personal Information
We and our affiliates do not share the personal information that you provide us with other organisations without your
express consent, except as described in this Privacy Policy. we and our affiliates disclose personal information to
third parties under the following circumstances:
Affiliates We and our affiliates may disclose your personal information to our subsidiaries and corporate affiliates (i.e.,our
family of companies that are related by common ownership or control) for purposes consistent with this Privacy Policy.
Professional Advisors and Service Providers. We and our affiliates may share information with those who need it to do work for us. These recipients may include third
party companies and individuals to administer and provide the Service on our behalf (such as bill and credit card
payment processing, customer support, hosting, email delivery and database management services), as well as lawyers,
bankers, marketing agencies, auditors, and insurers. For information about how they process your Personal Information
please refer to their Privacy Policy(ies).
Analytics vendors, including Google Analytics, in order to help understand how users interact with the Services, including to understand
users and potential users and their interests in Rooba products and services, to manage our relationship with users,
enhance user experience on our platform and applications, improve our platforms and applications. These services may
also collect information regarding the use of other websites, apps, and resources. You can learn about Google's
practices by going to www.policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at:
https://tools.google.com/dlpage/gaoptout.
Third Party Service Providers that assist us with carrying out the purposes we describe in this Privacy Policy. We
provide them information to facilitate services they provide to us. This includes providers of services such as website
hosting, information technology, auditing, and other services contemplated by this Policy. For the purposes of the
European Data Protection Laws, these service providers act as our processors.
To cooperate with law enforcement, protect our rights or those of third parties (for example, to detect and prevent
fraud), or as otherwise required by any applicable law;
In connection with, or during negotiations of, any merger, consolidation, restructuring, sale of company assets, or
disposition of all or a portion of our business to another company, including, without limitation, during the course of
any due diligence process; and
With other third parties when we and our affiliates have your consent.
Users in UK and EEA
The following information is only applicable to users located in the UK or the EEA or otherwise within the scope of
European Data Protection Laws.
Basis for Processing
We and our affiliates are allowed to process your Personal Information for the following reasons and on the following
legal bases:
To enter and perform a contract with you (i.e., the terms and condition of the Services) or to perform any steps you
require from us before entering into a contract.
To pursue our legitimate interests i.e. we and our affiliates have good, sensible, practical reasons for processing your
Personal Information which is in our interests. In this case, we use your Personal Information to provide you with the
Services as agreed in our Terms of Service with the entity on whose behalf you act or you directly. We also use the
Personal Information to establish, manage or conclude our business relationship with you or the entity on whose behalf
you act.
Where you have specifically consented to us processing your Personal Information.
To comply with our legal obligations and establish, exercise or defend our legal rights.
Where Personal Information is processed with consent, you may choose to withdraw your consent at any point by contacting
us as described below in the Contact Us section.
Right as a data subject,
As a data subject, you have the following rights under the European Data Protection Laws: .
Object to processing: You may object to us processing your personal information where we and our affiliates rely on a
legitimate interest as our legal grounds for processing your Personal Information.
Access personal data relating to you: You have the right to obtain a copy of your Personal Information as well as other
supplementary information (this largely corresponds to the information provided in this Privacy Policy). This is so that
you can understand how and why we are using your Personal Information and check we are doing it lawfully.
Rectification: You have the right to have inaccurate personal information rectified, or completed if it is incomplete.
Automated decision making: These rights do not apply as we and our affiliates do not make any automated decisions about
you
Restriction: You have the right to restrict us from processing your Personal Information in certain circumstances such
as where you are contesting the accuracy of your Personal Information or you have objected to us processing your
Personal Information. Whilst the restriction is in place we and our affiliates cannot do anything with the Personal
Information in any way except to store it.
Data portability: You have the right to receive personal information that you have provided us in order to share it with
a separate controller in a structured, commonly used and machine readable format. You can also request us to transmit
this information directly to another controller. This is only applicable where the lawful basis we and our affiliates
rely on to process your Personal Information is consent or for the performance of a contract.
Erasure: You have the right to request that we and our affiliates erase your Personal Information in certain
circumstances such as where your Personal Information is no longer necessary for the purpose which we and our affiliates
originally collected it for or we and our affiliates are relying on consent as lawful basis for holding your Personal
Information and you have withdrawn your consent.
Withdraw your consent: Where we and our affiliates have relied on your consent to process your Personal Information, you
have the right to withdraw the consent you have given us at any point. This is a vital and necessary aspect of consent.
To withdraw your consent, you can contact us at the details in the “Contact Us” section.
For you to exercise these rights, please get in touch with us using the information in the section Contact Us. We and
our affiliates will respond to any rights that you exercise within a month of receiving your request, unless the request
is particularly complex and/or if we receive a high number of requests, in which case we will respond within three
months.
Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in
accordance with the applicable laws. It is important that you ensure you have read this Privacy Policy - and if you do
not think that we have processed your Personal Information in accordance with this Privacy Policy - you should let us
know as soon as possible using the information at the section Contact Us.
Similarly, you may complain to the relevant supervisory authority in your country. In the UK this is the Information
Commissioner's Office, information about how to contact this regulator can be found at www.ico.org.uk. Ideally, we recommend that you get in touch with us first so we can resolve any issues directly with you as quickly as
possible.
Retention
The Personal Information we and our affiliates collect is stored on our servers or those of our service providers. We
and our affiliates retain Personal Information in accordance with our record retention policies. Our record retention
periods are established taking into account requirements of privacy laws, the purposes for which the information was
collected, legal and regulatory requirements to retain the information for minimum periods, limitation periods for
taking legal action, and our business needs. We and our affiliates may retain anonymous and aggregate information
indefinitely.
Transfer of Personal Information Outside UK and EEA
Any transfer of your Personal Information outside the UK and the EEA will be carried out in accordance with the European
Data Protection Laws to safeguard your privacy rights and give you remedies in the unlikely event of a security breach
or to any other similar approved mechanisms.
Security
Rooba.Finance uses physical, technological, and organisational security measures to help protect information about you
from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction. Our employees, representatives
and agents will have access to your Personal Information as necessary for the purposes described in this Policy.
Personal Information may be accessed by persons within our organisation, or our third party service providers, who
require such access to carry out the purposes indicated in this Policy, or such other purposes as may be permitted or
required by the applicable law. Personal Information we and our affiliates collect is managed in accordance with Indian
laws as notified from time to time.
However, while we and our affiliates have taken steps to help protect your Personal Information, we and our affiliates
cannot fully eliminate security risks associated with Personal Information. No security measures can provide absolute
protection. We and our affiliates cannot ensure or warrant the security of any information you provide to us.
By providing us with Personal Information, for users outside of the UK and EEA, you understand and expressly agree that
we and our affiliates may transfer your information to another country, including the US. If you are a user in the UK or
EEA, please refer to our section “Transfer of Personal Information Outside UK and EEA”. If you do not agree to the
transfer of your Personal Information outside of your jurisdiction, as described here, do not provide us with Personal
Information.
This Policy does not apply to third party sites
Our Services may contain links to websites owned by third parties. These other websites may have their own privacy
policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy
practices or the content of any website(s) owned and operated by third parties or our affiliates. Other websites may
collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy
for each website you visit. Any links from our Services to other websites, or references to products, services or
publications other than those of Rooba, do not imply the endorsement or approval of such websites, products, services or
publications by Rooba.
Access and Correction
You may request access to your Personal Information and to request a correction if you believe it is inaccurate. Please
contact us by e-mail at hello@rooba.finance if you would like to exercise either of these options. Please note that in
some circumstances we may not be able to allow you to access certain Personal Information, for example if it contains
Personal Information of other persons, or for legal reasons. We may require you to verify your identity before allowing
you to access your Personal Information.
Contact Us
If you have any questions about this Policy, please contact us:
Email: hello@rooba.finance
Phone: +91-81303 10333
You may also contact office at Spaze Itech Park , 1036 Tower B3, Sector 49, Gurugram, Haryana - 122018