Privacy Policy

 

M/S D2C INSURANCE BROKING PVT. LTD.  RESPECTS YOUR PRIVACY!

 

1. Introduction

This Privacy Policy sets out how the information provided by you is collected, used, stored, processed, transferred and protected. Please read the terms carefully. By accessing the Website or using any of our services, You agree to be bound by all the terms of this Privacy Policy.

For the purposes of this Privacy Policy, weus, our’, ‘DIBPL’ and “Company” refers to M/S D2C Insurance Broking Pvt Ltd (including its representatives, POSP Partners and Affiliates) and you refers to the employees both permanent and contractual in nature, probationers, contractors, vendors, agents, consultants, advisors, interns, trainees, customers and users of the services provided at all levels by the Company.

"Affiliate" means any Person directly, or indirectly through one or more intermediaries, that Controls, is Controlled by or is under common Control with DIBPL.

"Control," as used in the immediately preceding sentence, shall mean with respect to any person, the possession, directly or indirectly, of the power, through the exercise of voting rights, contractual rights or otherwise, to direct or cause the direction of the management or policies of the controlled person.

"Person" includes any natural person, corporation, partnership, Limited Liability Company, trust, unincorporated association, or any other entity.

By using our website-Renewbuy.com (“Website”)/mobile application-Renewbuy.com (“App”) and/or registering yourself at the Website/App or any other web domain owned by the Company, you authorize us to contact you via email or phone call or SMS or WhatsApp or any other electronic medium and offer you the services for the product(s) you have opted for based on your needs, impart product knowledge, offer insurance solutions, offer other promotional offers running on Website/App.   Irrespective of the fact that you have registered yourself under DND or DNC or NCPR service, by registering on the Website/App, you still authorize us to give you a call from RenewBuy, M/S D2C Insurance Broking Pvt Ltd, its affiliates, holding, subsidiaries and group companies, POSP partners, insurers associated with us or otherwise. By registration, you also authorize us to send Messages/SMS/Email alerts to you for your login details and any other service requirements or some advertising messages/emails from us. "If you are no longer interested in receiving e-mail announcements and other marketing information from us, or you want us to remove any information that we have collected about you, please e-mail your request to the Data Grievance Officer."

This policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage.

We understand and believe that the information provided by you is correct. However, please understand that the provisions of the services provided by us will be discontinued to you, at our sole discretion, if any information provided by you is untrue, inaccurate, out of date or incomplete or subsequently becomes untrue, inaccurate, out of date or incomplete, or there are reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete.

 

2. INFORMATION WE COLLECT

We will collect the following information from you:

a) Personal Information that will mean and include all kind of information which can be linked to a specific individual or to identify any individual, directly or indirectly, such as name, age, address, contact details (phone numbers/ email address), date of birth.

b) Clickstream data that includes information about your interaction with various elements of our Website and App.

c) If appropriate permissions are provided by you, we collect the GPS location on various platforms that you use the service on App/Website. Location might be collected at certain times that might depend on your App/Website usage or the time of the day.

d) Vehicle information whenever opting for motor insurance.

e) Health and lifestyle information which is collected only as per the requirements of the insurer to underwrite the proposal as per the guidelines of Insurance Regulatory and Development Authority of India (“IRDAI”) for health & life insurance.

f) Health and lifestyle related questions/information, which are mandated by the insurance company for the purpose of issuing insurance policy.

g) Details required in a KYC document which is the mandatory document as per the guidelines of IRDAI.

h) Documentary proof/information of educational qualifications, wherever applicable

i) Financial data including bank account number, IFSC Code. 

j) Constitution details of a vendor including without limitation, name, office address, Articles of Assocation.

k) Biometric Information, wherever applicable.

 

3. PURPOSE, USE AND STORAGE OF COLLECTED INFORMATION

The information/data collected (as mentioned above) may be used for analytics to ultimately improve our service offerings to you. It helps us to find geographical areas that might require a higher degree of support, provide appropriate leads or personalize the App/Website experience. The information/data is also collected for the purposes of providing proper services, verification of the identity and usage information.

Information collected will be used for the following purposes:

a) For issuance of the insurance policy that you have opted for.

b) For providing information about various products and services.

c) For addressing queries put forth by you and for resolving the concerns pertaining to any service or product.

d) For processing your transactions and also to provide you transaction and post transaction-related services.

e) For providing, improving, and marketing our products and services, including site content and performance.

f) For sending you survey and marketing communications.

g) For facilitating various programs and initiatives launched either by us or third party which we believe may be of an interest to you.

h) For facilitating usage of our Website/App.

i) For improving our services, product or content on our Website/App.

j) For providing group insurance cover and wellness corner offerings.

k) For providing health and wellness related information to you that are offered by insurer.

l) For sending notices, communications, offer alerts and to contact you over the telephone/  

 mobile number and/or e-mail address provided by you for sending information of our  

 products in which you have shown your interest, policy renewal reminders, other service

 details and other general information about insurance

m) For appointment as Point of Salesperson /employee.

n) For payment of salary/commission earned and related circumstances therein.

o) For verification purposes.

p) For the purpose of joining of the employee and for validation of the details of the curriculum vitiate.

q) For bank account details will be used for the purpose of salary/commission credit to employees/POSP and for payment to vendors/suppliers.

r) For biometric information for attendance purposes.

s) To improve our products and enhance customer service.

t) To extend services or administer a contest, promotion, survey or other site or business feature.

u) For Aadhaar authentication and sharing, storing, using Aadhaar data.

v) For sales and marketing Activities

w) Allow you to access specific account information.

x) To process transactions, where requested, under your User ID and Password. All the data/information collected may be stored on the infrastructure provided by third party cloud service in India which is fully compliant with regulatory requirements within. No information/data that is collected ever goes out of India.

 

4. INFORMATION SHARING AND DISCLOSURE

We will not share the information that we have collected from you to anyone other than as specifically noted herein below:

a) For the purpose of facilitating sale and servicing of insurance products to you, as an insurance broker, we provide your personal information to the insurers that are chosen by you on the App or Website.

b) Otherwise than stated in clause 4f herein below, we do not share or disclose the information to any other individual/institutions and their subsidiaries/associates/holding company/ subsidiaries companies/ group companies/ affiliates, tie-up institutions etc. for any purpose unless such a disclosure is explicitly authorised by you. D2CIB Response- We have suitable changes in wordings.

c) Where information collected by us is required to be disclosed to comply with any applicable law, regulation and legal process;            in response to law enforcement authority or other governmental official request; to detect, prevent, or otherwise address fraud, cyber incidents, prosecution, and punishment of offences; for security or technical issues; to investigate a complaint or security threat and for any public interests.

d) For marketing purpose but only under circumstances where you have specifically authorized or consented for the same.

e) Where we are required to disclose the information as a part of any statutory obligation to IRDAI or any other statutory authority.

f) We may share and/or transfer your information to any of our Affiliate, holding/ subsidiaries/ group companies  and/or insurers. Our affiliates, holding/ subsidiaries/ group companies may also from time to time send by e-mail or otherwise, information relating to their products or services.

g) We may also share and/or transfer your information to any successor-in-interest as a result of a sale of any part of our business or upon the merger, reorganization or consolidation of DIBPL with another entity on the basis that DIBPL is not the surviving entity.

h) We may share personal information with our other corporate entities and affiliates to help us operate our business and the Site or administer activities such as detection of identity theft, fraud and other potentially illegal acts, to facilitate joint or co-branded services that you request where such services are provided by more than one corporate entity. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

Where you provide Personal Information of beneficiaries/dependents/other individuals to the Company, you agree (i) To inform the individual about the content of this Privacy Policy and (ii) to obtain any legally-required consent of Personal Information about the individual in accordance with this Privacy Policy

 

5. RIGHTS UNDER THE POLICY 

The below mentioned rights can be exercised by you as and when we obtain or hold personal information about you, or access personal information we hold about you, and for obtaining its correction, update, amendment, or deletion in appropriate circumstances where permitted by applicable law or regulation. Some of these rights may be subject to some exceptions or limitations.

  1. You have the right to Access your personal data held about you and to learn the origin of the data, the purposes and means of the processing, the details of the data controller(s), the data processor(s) and the parties to whom the data may be disclosed.
  2. Withdraw your consent at any time where your personal data is processed with your consent.
  3. Update and correct your personal data so that it is accurate;
  4. Delete your personal data from our records if it is no longer needed;
  5. Restrict the processing of your personal data in certain circumstances, e.g. where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy;
  6. Obtain your personal data in an electronic format;
  7. File a complaint with us and/or the relevant data grievance officer; and
  8. Object to us processing your personal data, or tell us to stop processing it (including for purposes of direct marketing, survey etc)

The above rights can be exercised by you by approaching to the Data Grievance Officer.

 

6. SECURITY MEASURES

Protection of your information is of paramount importance to us.We adopt appropriate data collection, storage and processing practices and security measures to protect against any unauthorized access, alteration, disclosure or destruction of your information, username, password, transaction information and any other information/data stored with us. Some of the security measures taken by us are as following:

a) The information collected by us is stored on servers that are secured behind a firewall. Further, the access to the servers is password-protected and is strictly limited.

b) All information transmitted to and from our server is fully encrypted.

c) The data that is passed in APIs is passed over secure TLS based http connection. 

d) We do not store any payment or cards related information on our servers. Your data stored in our systems is not visible to anyone. 

e) We are ISO27001:2013 certified.

f) The system architecture isolates insurer code to ensure that there is no possibility of cross-talk between insurer systems.

g) All the communication with insurer is push-based, i.e. only required information is pushed to the insurer system. Insurer cannot pull out data from the system of RenewBuy.

h) Each proposal and the transaction that is done is tagged to a customer and agent through an email id which is then protected by a password. A policy will be accessible only to an agent or the customer.

i) Your personal information in RenewBuy account is not visible to anyone. End-to-End encryption is used to transmit data between all entities, to protect against network vulnerabilities.

 

7. UPDATE/CORRECTION/DELETION OF INFORMATION

You have the right to access your personal information. You also have the right to request correction and deletion of the information shared by you. Changes can be made in system as and when there is any requirement for a change in the information. Personal information can be corrected, deleted or amended by contacting us. We will make efforts in good faith to make requested changes in our then-active databases as soon as reasonably possible. Thus, you may contact us through the Grievance Officer to have your information updated/corrected/deleted with us.

 

8. RETENTION PERIOD

All information collected by us will be stored with us as long as it is necessary for us to fulfill our obligations in respect of the provision of the services and in accordance with the applicable laws. Information collected by us can be retained by us if we believe it to be necessary to prevent fraud or future abuse; if required by law, for other legitimate purposes.

 

9. CONSENT

By using our Website/App and by providing your information, it is assumed that you have provided your express consent to the collection and use of the information which is disclosed in accordance with this Privacy Policy, including but not limited to, your express consent for sharing this information as per this Privacy Policy. We recommend that you do not use/access and/or continue to use/access the Website/App if you do not agree to the terms and conditions of this Privacy Policy. We obtain your consent depending on our relationship with you. Thus, the consent is obtained in the following manner:

a) Consent of prospects/customers: Consent of the customer is taken on the proposal form/ through acceptance of the terms and conditions of our App or website.

b) Consent of Partners/POSP: Consent of the Partner/POSP is obtained through execution of the agreement with the Company/acceptance of  the terms and conditions of our App or website during enrolling stage.

c) Consent of Vendors/Suppliers: Consent of the vendor/supplier is obtained by execution of the agreement with the Company and through various others self-attested documents/ questionnaire.

d) Consent of the Employees: Consent of an employee is obtained through the forms filled up by an employee at the time of joining through the joining documents and/ or through self-attested testimonials and other KYC documentation.

By using our website or by providing your information as mentioned above, it is assumed that you have provided your express consent to the collection and use of the information, which is disclosed in accordance with this Privacy Policy, including but not limited to, your express consent for sharing this information as per this Privacy Policy. We recommend that you do not use/access and/or continue to use/access the website, WAP service or app if you do not agree to the terms and conditions of this Privacy Policy You have an option to refuse giving your consent or take back your consent in a way as specified below:

a) Customers can choose not to continue buying our product/services and drop the transaction by not making payment.

b) Vendors have the right to terminate the contract or modify the terms of the contract while the same is in force.

c) Partners/POSP can drop the decision to become a Partner or after becoming a Partner, request for termination can be made and NOC can be taken from us with respect to the same.

d) Employee has the option to not join the Company or if the employee has joined the Company, he/she can modify the information submitted to us.”

 

10. COOKIES

A cookie is a small text file that is stored on a computer for record-keeping purposes. We use cookies and other technologies such as pixel tags and clear gifs to store certain types of information each time you visit any page on our Website/App. Cookies enable to recognize the information you have consented to give to Website/App and help us determine what portions of our Website/App are most appropriate for your professional needs. We may also use cookies to serve advertising banners to you. These banners may be served by us or by a third party on our behalf. These cookies will not contain any personal information.

Whether you want your web browser to accept cookies or not is up to you. If you haven't changed your computer's settings, most likely your browser already accepts cookies. If you choose to decline cookies, you may not be able to fully experience all features of the Website/App. You can also delete your browser cookies or disable them entirely. But this may significantly impact your experience with our Website/App and may make parts of the Website/App non-functional or inaccessible. We recommend that you leave them turned on.

Third Party Cookies Third parties may place cookies on this RenewBuy site. The information practices of these third parties are not covered by our Privacy Policy. Please contact them directly for more information about their privacy practices. Also, as described above, you may modify the settings in your browser to notify you when you receive a new cookie and disable cookies altogether.

 

11. OTHER SITES

There might be affiliates or other sites linked to our Website/App. Thus, when you visit those sites, the affiliated sites may have different privacy practices and we encourage you to read their privacy policies. These sites may place their cookies or other files on your computer, collect data or solicit personal information.

 

12. ACCEPTANCE OF THESE TERMS

By using our Website/App, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy policy, please do not use our Website/App. Your continued use of our Website/App following the posting of changes to this Privacy Policy will be deemed as your acceptance of those changes.

 

13. DATA GRIEVANCE OFFICER

In case you have any grievances with respect to in accordance with applicable law on Information Technology and rules made there under, the name and contact details of the Grievance Officer are provided below:

Name: - Mr. Pankaj Tiwari

Designation: - AVP - Information Technology

Address: - Plot No. 94, First Floor, Sector-32, Gurugram -122001, Haryana

Email: - data-grievance@renewbuy.com

For any queries or grievances pertaining to this privacy policy or collection, storage, retention or disclosure of your information under the terms of this Privacy Policy, you can contact to the Grievance Redressal Officer at data-grievance@renewbuy.com.

Not-withstanding anything mentioned before, we reserve the right to contact you via any mechanisms, not limited to email, sms, or phone calls, to solicit feedback of your experience and to provide any additional services that you would be eligible for, either as a customer or as a visitor. We should not be held liable for any damages occurring to you as part of feedback solicitation and additional service provision.

 

14. CHANGES TO THIS PRIVACY POLICY 

M/S D2C Insurance Broking Pvt Ltd reserves the right to amend or modify this Privacy Policy at any time, as and when the need arises. We request you to regularly check this Privacy Policy from time to time to keep you apprise of changes made. Your continued use of the Website gives your unconditional acceptance to such change in terms of Privacy Policy

 

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