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CoPay Mobile Application Privacy Policy
This Privacy Policy is for the products/services under the brand "CoPay" which is owned by Information Technology Co-operative Society (ITCS) (hereinafter both together called "Copay Service Provider") and is effective as of July 1st, 2017.

Introduction
Copay Service Provider is committed to protect your privacy, and we understand that you care about how your personal information is used or shared. Just like you, we do not want anyone to misuse your personal information, so we have ensured that it is safeguarded securely.

Scope of this Policy
This Privacy Policy ("Policy") applies to those who use CoPay Mobile App(s) and visit our website itcsm.com ("Website"), as well as users ("Customer") of our Mobile App, online Tools and Service(s) ("Services"). It describes how Copay collects, uses, shares and secures the personal information you provide. It also lists your choices regarding use, access and correction of your personal information. The capitalized terms used in this Policy but not defined herein shall have the same meaning as defined in our Terms of Service ("Terms").
In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity. The use of information collected through our Services shall be limited to the purpose of providing the service for which the Customer has engaged Copay.
By using our App, Services and Website, you agree and accept the terms outlined in this Policy.
What Personal Information About Users Does CoPay Gather?
Information That You Provide To Use
Personal Information
When registering for an account to access and use one or more of our Services, Copay asks and collects your personal information that you voluntarily provide, such as your name, address, phone number, email address, Bank Account number, Bank Name and website name. Copay uses the collected information to provide products and services to you, which involves creation of user profiles, billing, authentication, contact and improvement to said products, services and its websites.

We refer to any information described above as "Account Information" for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal data or are otherwise authorized to provide it to us.

Bank Account Details
We collect your bank account details to provide the necessary services of Copay. These bank account details are kept secured and is visible to you and for to the Copay Service Provider for providing business service and support.

Credit Card Details
We also collect your credit card / wallet details whenever necessary for the paid of our Services Copay.

Information That We Collect From You Automatically
We receive and store certain types of information whenever you interact with us through Mobile App or Website. For example, like many websites, we use "cookies", and we obtain certain types of information when your Web browser accesses the Sites. Examples of the information we collect and analyze include the Internet protocol (IP) address used to connect your computer to the Internet; your e-mail address; computer and connection information, such as browser type and version, operating system and platform; the full Uniform Resource Locators (URL) clickstream to, through and from our website, including date and time; cookie number; and pages you viewed or searched for. Copay uses this information to improve its websites, products and services and your experience with Copay.

What About Cookies?
Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser to enable our systems to recognize your browser and to provide features such as personalization and enhance your experience on the Website. We also collect/use specialized Tokens in a similar manner of cookies. Copay uses cookies to identify visitors and track visits to our website, store login session information and to remember your user preferences.
The "Help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, cookies allow you to take full advantage of the Copay's features and disabling them may affect the quality of your experience on the Copay
You can set your browser to either reject all cookies, to allow only "trusted" websites to set them, or to accept only those cookies from those websites you are currently on.
For more information on controlling cookie settings in your browser, please refer to the following links:

[NOTE: Other things that can be included are Mobile Applications, Web Beacons, Analytics, Local Storage Objects, Logs, Socila Media Widgets, Single Sign On]

How Does Copay Use Information Collected From You?
Copay uses the information collected from you primarily to provide you basic and personalised service and enhanced experience on the Mobile App, Website and its Services. The information will be further used internally to improve the Services and develop new products, services and features, send you communications from the Services, respond to customer service requests, administer your account, send you promotional and marketing communications, respond to your queries and concerns and facilitate your transactions with other users when you use our Services.

Does Copay Share the Information It Receives?
Information about our users is an important part of our business, and we are not in the business of selling, sharing or leasing that information to others. We share user information only as described below and only with subsidiaries that Copay Service Provider controls.

  • With Your Consent: By accepting the Terms, you expressly consent to our use of your information as outlined in this Policy.
  • Service Providers and Agents: We employ other companies and individuals to perform functions, such as analyzing data, processing payments and providing customer service, on our behalf. These parties are granted access to the information needed to perform their functions but may not use it for other purposes.
  • • Internal Teams: Copay may disclose personally identifiable information to its employees, contractors and affiliated organizations. This will only be done on a need-to-know basis. Copay uses the services of third party vendors for storage, network and technical services. Personally identifiable information may be transferred outside of your home country as part of our provision of services to you.
    • o Copay reserves to right to publish correspondence and feedback sent to us in order to help us respond to the correspondence or to help other users. Copay will take all reasonable measures to protect against unauthorized access, use and alteration to personally identifiable information. When passing personally identifiable information to a third party, we will ensure that adequate protection of the information is applied by the recipient.
  • Business Transfers: As we continue to develop our business, we might sell or buy additional services or business units. In such transactions, user information generally is one of the transferred business assets, although it remains subject to the promises made in any pre-existing Policy (unless the user consents otherwise). In the event that Copay or substantially all of its assets are acquired, user information will be one of the transferred assets.
  • Protection of Copay and Others: We may release account and other personal information when we believe such release is appropriate to comply with the law; enforce or apply our Terms of Service or other agreements; or protect the rights, property or safety of Copay, our Users or others. This includes (1) exchanging information with other companies and organizations for fraud protection and credit risk reduction and (2) releasing your name and address to requesters for whom you provide Services so that those requesters can comply with tax and other legal obligations they might have if you are a provider of a Service on the Copay. This clause does not include selling, renting, sharing or otherwise disclosing personally identifiable information from users for commercial purposes in violation of the commitments set forth in this Policy.

How Does Copay Protect Information About Me?
We work to protect the security of your information during transmission by using Secure Socket Layer (SSL) software, which encrypts information you input.
We take reasonable measures to protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that despite our efforts, no security or procedural measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse.

What Choices and Access Do I Have?
We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non- transactional communications by clicking on the "unsubscribe" link located on the bottom of our marketing emails or in our website or you may send a request to copay@itcsm.com.
As discussed above, you can always choose not to provide information, even though it might be needed to take advantage of the Copay App, Websites and/or Services. You are free to change any of the personally identifiable information that you have provided to us by logging into the Copay.
If you would like us to delete any personally identifiable information about you, we will do so on request unless we need to hold the information as part of the provision of products and services to you. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at copay@itcsm.com.

Links to Third-Party Sites
Our Mobile App, WebSites and Services may contain links to Third-Party Sites. This Policy does not apply to Third-Party Sites, and any information you provide on the linked pages is provided directly to that third party and is subject to that third party's privacy policy. We are not responsible for the privacy and security practices and policies of any sites that are linked to from the Sites or through the Services. We encourage you to learn about the privacy and security practices and policies of Third-Party Sites before providing them with personal information.

What is the Update Policy?
Any updates to this policy will be posted to this URL and will be effective from the time of posting, users may time-to-time check the policy from the link provided in the Copay App. We will notify the primary Copay Service account holder by email or by Mobile App when significant changes are made to the Policy prior to the change becoming effective.
We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of this site following the posting of any amendment, modification, or change shall constitute your acceptance of the amendment. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Copay App, Websites and the Services.

Handling of Inquiries, General Concerns and Complaints
If you have any concern about privacy at Copay, please contact us with a thorough description of your concern, and we will try to resolve it. Pursuant to this Privacy Policy and the Terms of Service, you agree not to pursue Copay through any means, including regulatory agencies, courts or the media, until and unless Copay Service Provider has had a minimum of 30 days to respond to the initial communication and while Copay Service Provider and you are conducting a dialogue about the matter.
Our business changes constantly, and our Privacy Policy and the Terms of Service, may also change. We may email periodic reminders of our notices and conditions, but you should check the Copay Sites frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.

How To Contact Us
If you have any queries regarding Copay's Policy or information practices, please feel free to contact us by sending us a mail to the following address:
• Address: Information Technology Co-operative Society Ltd., Registered Office: First Floor, UMK Tower, Jubilee Road,Uphill Malappuram - 676 505 Kerala , India • Telephone: +91-483-2732703/2738743 • Email: copay@itcsm.com