Privacy Policy
Privacy Policy
Pouring Pounds Limited and/or Pouring Pounds India Private Limited (referred to as “We,” “Our,” “REFERB2C” or “Us,” and including our respective legal heirs, representatives, administrators, permitted successors, and assigns where applicable) own and operate the website and mobile application, ReferB2C.com (“Website” or “Site”).
In order to provide our services (as outlined in Clause 1), REFERB2C is required to collect, store, and transmit certain information from users of the Website (“Users”). This Privacy Policy (“Policy”) explains how we collect, use, share, and protect the personal information of those using our services (collectively referred to as “You,” “Your,” or “Users”).
We created this Privacy Policy to demonstrate our commitment to safeguarding the privacy of users who engage with our services. Your use of and access to these services is governed by this Privacy Policy and our Terms and Conditions. Any capitalized terms not defined in this Privacy Policy shall have the meaning attributed to them in our Terms and Conditions.
Please note, the headings in this document are for organizational purposes only and should not be interpreted as limiting or expanding the clauses contained within.
1. Definitions
In this Privacy Policy, unless the context otherwise requires, the terms defined shall bear the meanings assigned to them below, and their cognate expressions shall be construed accordingly.
- “Personal Information” shall have the same meaning as given in Rule 2(1)(i) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person.
- The SPI rules further define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:
- Passwords;
- Financial information such as bank accounts, credit and debit card details, or other payment instrument details;
- Physical, physiological, and mental health conditions;
- Sexual orientation;
- Medical records and history;
- Biometric information;
- Information received by body corporate under lawful contract or otherwise;
- Visitor details as provided at the time of registration or after that; and
- Call data records.
- “You”, “Your”, “Yourself” and “User” shall mean and refer to natural & legal individuals and legal entities/companies who visit and use the services and will also include the individuals/entities/companies who avail the services by submission of details by some other person.
- “Third Parties” refer to any website/application/web portal, company, or individual apart from the user and us.
- “Services” shall mean the Website (https://ReferB2C.com/) and Mobile Application (REFERB2C) and contextual information transmitted to/ received from Users via various communication channels including but not limited to e-mail, SMS, WhatsApp, phone calls, website chat, IVR. We are primarily engaged in the business of allowing Users to share customized links for various products in the network of such Users, the customized links drive sales to e-commerce websites and in turn, the Users earn cashback. We currently operate under the brand name REFERB2C.
- “User Information” shall mean Personal Information and Sensitive Personal Data or Information.
- “Website” shall mean and refer to https://ReferB2C.com/, the “Application” and/ or “App” shall refer to the REFERB2Cmobile application available on the Android Play Store or iOS App Store. These shall be collectively referred to as the “Platform".
2. Why this Privacy Policy?
This Privacy Policy is published in compliance with, among other things,
- Section 43A of the Information Technology Act, 2000;
- Regulation 4 of the SPI Rules; and
- Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 (“Intermediaries Guidelines”).
This Privacy Policy states, among other things, the following:
- The type of information collected from the Users, including Sensitive Personal Data or Information;
- The purpose, means, and modes of usage of such information; and
- How and to whom we will disclose such information?
3. General
The user unequivocally agrees that this policy and the aforementioned Terms and Conditions constitute a legally binding agreement between the user and ReferB2C, and that the user shall be subject to the rules, guidelines, policies, terms, and conditions applicable to any service that is provided by ReferB2C including the Services, and that the same shall be deemed to be incorporated into the Terms and Conditions, and shall be treated as part of the same.
4. Collection and handling of personal information
Privacy of the Parties is of prime importance to Us and all Services are strictly designed within the jurisdiction of laws defined by the Government of India. Generally, the services require us to know who you are so that we can best meet your needs. When you access the Services, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
- Contact data (such as your email address and phone number);
- User name and passwords;
- Demographic data (such as your name, gender, age, date of birth, and your pin code);
- Data regarding your usage of the services and other transactions made by or with you through the use of Services;
- Information about your clicks on and from ReferB2C mobile device, web browser, web and mobile browsing patterns, retailer preferences
- Your bank account information including the name of the bank account, account number, IFSC code, bank branch, or any other payment-related information
- Any other information that you voluntarily choose to provide to us (such as information shared by you with us through emails, calls, or letters, your work details, home/work address, your family details, details about transactions done on e-commerce sites, screenshots of transactions, order IDs for transactions, alternate numbers and emails and various other information provided from time to time).
The information collected from You by Us shall constitute ‘Personal Information’ or ‘Sensitive Personal Data Information’ under the SPI Rules.
5. PRIVACY STATEMENTS
5.1. The User expressly agrees and acknowledges:
- Information that is freely available in the public domain or accessible under the Right to Information Act, 2005, or any other law will not be considered as ‘Personal Information’ or ‘Sensitive Personal Data or Information’ for this Policy. That REFERB2C may automatically track information about the User based on the User’s IP address and the User’s behavior on the Platform, and the User expressly consents to the same. The User is aware that this information may be used to conduct internal research on user demographics, interests, and behavior, to enable REFERB2C to better understand, and cater to the interests of the Users. Further, the User is expressly made aware that such information may include the User’s computer & web browser information, the User’s IP address, mobile device details, etc. The linkage between the User’s IP address and the User’s personally identifiable information may be shared with or disclosed to third parties to facilitate the provisions of the Services to You. The User hereby consents to the sharing of such information to such third parties as may be determined by REFERB2C from time to time. Further, we may also share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with third parties for market research and new feature development.
- That any information about the User collected by REFERB2C, whether or not directly provided by the User to REFERB2C, including but not limited to personal correspondence such as emails or letters SMS WhatsApp or calls, feedback from other users or third parties regarding the User’s activities or postings on the Platform, etc., may be collected and compiled by REFERB2Cinto a file/folder specifically created for/allotted to the User, and the User hereby expressly consents to the same. Also, to keep You informed of Your activities on the Website we occasionally send You emails, SMS, App notifications, and other marketing communication. These include Your transaction messages to show how much You have earned, referral messages that show You how much You have earned from referrals, payment confirmations for payments to You, and, important administrative messages and messages to confirm Your activities on the Website. These emails are not shared with anyone else apart from You. We also send newsletters, SMSs, App notifications, browser notifications, and other marketing that feature some of our best ideas to help You save more. You may choose not to receive this marketing communication from REFERB2C by informing Us at any time. We do not support spamming by our members and we explicitly prohibit it in our Terms and Conditions. If You would like to report an incident of spamming, please contact us so we can investigate and take suitable action.
- That the contact information provided to REFERB2C may be used to send the User offers and promotions, whether or not based on the User’s previous interests, and the User hereby expressly consents to receive the same. The User may choose to unsubscribe from promotional communications by clicking on the ‘unsubscribe’ link provided at the end of such promotional communication or by emailing us at support@ReferB2C.com
- REFERB2Cmay occasionally request the User to complete optional online surveys. These surveys may require the user to provide contact information and demographic information (like zip code, age, income bracket, sex, etc.). The user is aware that this information is used to improve/customize the Services for the benefit of the user and provide all users of the platform with services that REFERB2C believes they might be interested in availing of.
- That ReferB2C may keep records of electronic communications and telephone calls received and made for support or other purposes for administration of Services, customer support, research and development, and for better assistance to users.ReferB2C may occasionally request the User to write reviews for services availed of by the User from the Platform. The user is aware that such reviews will help potential users of the Platform in availing the Services, and the User hereby expressly authorizes ReferB2C to publish any reviews written by the User on the Platform, along with the User’s name and certain contact details, for the benefit and use of other users.
- Nothing contained herein shall be deemed to compel ReferB2C to store, upload, publish, or display in any manner content/reviews/surveys/feedback submitted by the User, and the User hereby expressly authorizes ReferB2C to remove from the Platform any such content, review, survey, or feedback submitted by the User, without cause or being required to notify the User of the same.
- Generation and collection of ‘Sensitive Personal Data or Information’ by the Information Technology Act, 2000 as amended from time to time and allied rules requires the User’s express consent. By affirming assent to this Policy and clicking on the “I agree with Terms and Policy” button at the time of registration, the User provides consent to such generation and collection as required under applicable laws.
- The User is responsible for ensuring the accuracy of the information submitted to ReferB2C. The User may correct, delete inaccuracies, or amend information by contacting ReferB2C through email at support@ReferB2C.com. REFERB2C will make good faith efforts to make requested changes in the databases as soon as reasonably practicable. If the User provides any information that is untrue, inaccurate, out of date, or incomplete (or becomes untrue, inaccurate, out of date, or incomplete), or REFERB2C has reasonable grounds to suspect that the information provided by the User is untrue, inaccurate, out of date or incomplete, REFERB2C may, at its sole discretion, discontinue the provision of the Services to you as per the provisions laid down in the Terms and Conditions. There may be circumstances where Pouring Pounds will not correct, delete, or update your Personal Data, including (a) where the Personal Data is opinion data that is kept solely for evaluative purposes; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
- All the information provided to Us by a User, including Sensitive Personal Data or Information, is voluntary. User has the right to withdraw his/ her/ its consent at any time, by the terms of this Privacy Policy, and the Terms and Conditions applicable to such user, it being however clarified that withdrawal of consent will not be retroactive. If the User wishes to delete his/her account or request that REFERB2C no longer uses the User’s information to provide Services, the User may contact REFERB2C at support@ReferB2C.com. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After some time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes. Please note that your withdrawal of consent, or cancellation of account may result in Pouring Pounds being unable to provide you with its Services or to terminate any existing relationship Pouring Pounds may have with you.
- If you wish to opt out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please email us at support@ReferB2C.com.
6. Our use of your information
All the information provided to REFERB2C by a User, including Personal Information or any Sensitive Personal Data or Information is voluntary. Such information in its original form may be shared with any Third Parties in furtherance of the consent from the User as provided hereunder. You understand that REFERB2C may use certain information of yours, which has been designated as Personal Information or ‘Sensitive Personal Data or Information’ under the SPI Rules for the following purposes:
- Providing you the Services;
- Taking product & service feedback;
- For offering new products or services and marketing of the Services;
- For analyzing software usage patterns for improving product design and utility;
- For providing the services of generating alerts/reminders/SMS for offers and also for internal records.
- For commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis, and business intelligence purposes,
- For sale or transfer of such research, statistical, or intelligence data in a non-personally identifiable form to third parties and affiliates;
- Debugging customer support-related issues; We may use your tracking information such as IP addresses, and or Device ID to help identify You and to gather broad demographic information.
In case we are acquired by or merged with another company, We shall transfer the information disclosed by You and the information about You to the company we are acquired by or merged with, and such company will have the right to continue to use the user’s Personal Information and/ or other information that a User provides to Us. In the event of a merger or acquisition, We shall notify You by email/by putting a notice on the Website and/ or application before Your Personal Information is transferred and becomes subject to a different privacy policy.
- To government institutions/ authorities to the extent required:
- Under the laws, rules, regulations, and orders of any relevant judicial or quasi-judicial authority;
- To protect and defend the rights or property of REFERB2C
- To fight fraud and credit risk;
- To enforce REFERB2C’s Terms and Conditions applicable to the Users; or
- When REFERB2C in its sole discretion, deems it necessary to protect its rights or the rights of others.
- If otherwise required by an order under any law for the time being in force including in response to inquiries by government agencies for verification of identity, Or prevention, detection, investigation including cyber incidents, prosecution, and punishment of offenses. However, We contract with third parties to serve ads on our behalf across the Internet and sometimes on this site. They may collect information about Your visits to our website, and Your interaction with our products and services. They may also use information about Your visits to this and other websites to target advertisements for goods and services. This information is collected through the use of a pixel tag, which is industry standard technology used by most major websites. Such third parties are not permitted to sell or share Your personally identifiable information The following third-party vendors, including Google, and Facebook, advertising platforms, remarketing platforms like CleverTap and customer query management platforms like Freshworks & Exotel use cookies to serve ads based on a user's prior visits to Your website. Google's use of the DoubleClick cookie enables it and its partners to serve ads to your users based on their visits to your sites and/or other sites on the Internet.Users may opt out of the use of the DoubleClick cookie for interest-based advertising by visiting Ads Settings.
7.1. Your information is regarded as confidential and therefore shall not be divulged to any Third Parties unless provided hereunder and unless legally required to do so to the appropriate authorities, or if necessary, for providing the Services through the Platform.
7.2. Your Personal Information/Sensitive Personal Data is maintained by Us in an electronic form on our equipment, and on the equipment of our employees. Such information may also be converted to physical form from time to time.
7.3. People who can access your Personal Information
User Information will be processed by our employees, authorized staff, marketing agencies, or agents, on a need-to-know basis, depending on the specific purposes for which the User Information has been collected by Us. REFERB2C may, therefore, retain and submit all such records to the relevant stakeholders.
7.4. Security Practices. We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by members inside and outside REFERB2C. We follow generally accepted industry standards to protect the User Information submitted to Us and information that We have accessed, including managerial, technical, operational, and physical security control measures. However, for any data loss or theft due to unauthorized access to the User’s electronic devices through which the User avails the Services, We shall not be held liable for any loss whatsoever incurred by the User.
7.5. Measures We expect you to take: It is important that you also play a role in keeping your User Information safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered, and make sure to log out of your account every time you leave the computer. You should also use any privacy settings or controls We provide you on Our Platform.
7.6. Unauthorised use of User’s account. We do not undertake any liability for any unauthorized use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify Us by sending an email to support@ReferB2C.com.
7.7. Notwithstanding the above, REFERB2C is not responsible for the confidentiality, security, or distribution of your Personal Information by third parties outside the scope of our agreement with such third parties. Further, REFERB2C shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of REFERB2C including but not limited to the acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption.
8. Retention of your data
By applicable laws, We will use the User Information for as long as necessary to satisfy the purposes for which such User Information was collected (as described in Section 4 above) or to comply with applicable legal requirements.
9. Your rights
9.1. Access to Personal Data. You have the right to access, review, and request a physical or electronic copy of information held about you. You also have the right to request information on the source of your Personal Information/Sensitive Personal Information.
9.2. Additional rights (e.g. modification, deletion of Personal Data). Where provided by law, you can (i) request deletion, the portability, correction, or revision of your User Information; (ii) limit the use and disclosure of your Personal Data; and (iii) revoke consent to any of our data processing activities. Provided that, we may be required to retain some of your User Information after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your User Information to satisfy our business needs.
10. Children's and minor's privacy
We strongly encourage parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools can also prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Services are not intended for use by minors, We respect the privacy of minors who may inadvertently use the internet or the mobile application.
11. Consent of the policy
You acknowledge that this Privacy Policy is a part of the Terms and Conditions of the Website and the other Services, and you acknowledge that you have unconditionally agreed as User of the Platform and the Services signifies your consent to this Privacy Policy. Your visit to the Website, use of the App, and use of the Services is subject to this Privacy Policy and the Terms and Conditions.
12. Cookies
When You avail of our Services on the Platform, a persistent cookie is placed on Your computer. This enables us to track any purchases You make with our participating retailers and award cashback/rewards/points to You. If You do not have such persistent cookies enabled on Your computer You will not be able to earn cashback/points on Your online shopping via Our Platform.
Disabling/enabling cookies: You can accept or decline cookies by modifying the settings in Your browser. However, You may not be able to use all the interactive features of Our Platform if cookies are disabled.
Please note: If you disable the cookies in Your browser which are used to track Your purchases via Our Platform, You will not be able to earn cashback/points when You shop from our website.
There are several ways to manage cookies. If You use different computers in different locations You will need to ensure that each browser is adjusted to suit Your cookie preferences.
You can easily delete any cookies that have been installed in the cookie folder of your browser. For example, if you are using Microsoft Windows Explorer:
- Open 'Windows Explorer'
- Click on the 'Search' button on the toolbar
- Type "cookie" into the search box for 'Folders and Files'
- Select 'My Computer' in the 'Look In' box
- Click 'Search Now'
- Double-click on the folders that are found
- 'Select' any cookie file
- Hit the 'Delete' button on your keyboard
If you are not using Microsoft Windows Explorer, then you should select "cookies" in the "Help" function for information on where to find your cookie folder
13. Affiliate commision
REFERB2C, an affiliate platform, is essentially a service provider that connects retailers and publishers. REFERB2C is not liable to pay for any commission that is canceled by the partner retailer due to any reason whatsoever and not limited to bulk buying, self-consumption, unattributed sale, return or cancellation of product, and violating any affiliate policy of our partner retailer. Users are required to constantly keep a check on profit rates and terms of campaigns as these are subject to change in real-time without prior notice. REFERB2C reserves the right to cancel the profit as directed by the partner retailer. By
signing up on REFERB2C, the user agrees to abide by this clause.
14. Amendments and changes to Privacy Policy
REFERB2C may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way REFERB2C treats User Information, or in the Privacy Policy itself, REFERB2C will display a notice on the website or send users an email, as provided above, so that the user may review the changed terms before continuing to use the services. As always, if the user objects to any of the changes to our terms, and the User no longer wishes to use the services, the user may communicate the same to support@ReferB2C.com to deactivate your account. Unless stated otherwise, the current Privacy Policy applies to all information that REFERB2C has about you and your account.If a user uses the services after a notice of changes has been sent to such User or published on the platform, such user hereby provides his/her/its consent to the changed terms.
15. ADDRESS FOR PRIVACY QUESTIONS Should You have any questions about this Privacy Policy or REFERB2C’s information collection, use, and disclosure practices.You may contact, the Data Protection Officer appointed by REFERB2C. We will use reasonable efforts to respond promptly to any requests, questions, or concerns, which You may have regarding our use of Your Personal Information. If You have any grievance concerning our use of your information, you may communicate such grievance to the Data Protection Officer: e-mail: support@ReferB2C.com