Privacy Policy

This privacy policy (Privacy Policy) explains our policy inter alia regarding the collection, use, disclosure, security and transfer of your information collected/stored by and/or its subsidiary(ies) and/or affiliate(s) (collectively referred to as the ‘wealthup.me’) which operates the Wealthup.me mobile application platform (Platform) and other services including but not limited to real time group-payment settlement system and other related services (collectively the “wealthup.me Service” or “Services”).

This Privacy Policy forms part and parcel of the Conditions of Use for the Wealthup.me Platform and Services. Capitalized terms which have been used here but are undefined shall have the same meaning as attributed to them in the Conditions of Use. By using the Platform, you agree to the terms of this Privacy Policy. Whenever you submit information or avail any Services on the Platform, you consent to the collection, use and disclosure of the information in accordance with this Privacy Policy.

We take the privacy of our users seriously. We are committed to reasonably safeguarding the privacy of our users while providing a personalised and valuable Services. The information about the user as collected by wealthup.me is: (a) Information supplied by users, including third-party information and personally identifiable information (“Personal Information’), on the Platform and/or on the Website and (b) Information automatically tracked while using the Platform; (collectively referred to as “Information”)

1. Information supplied by users

a) To avail certain services on the Platform, users are required to provide some “Personal Information” for the registration process and creation of wealthup.me Account which may include:-

  1. Your Name
  2. Email Address
  3. Phone Number
  4. Access to your phone's SMS inbox records
  5. Surveys that you complete through the Website or Platform or based on our request
  6. Furnishing information for the purpose of Know-Your-Customer (KYC) including but not limited to personal identification number of AADHAR, PAN, voter identification etc.
  7. Date of birth
  8. Picture for the display
  9. Any other such information as required.

The Information as supplied by the users enables us to provide the Services, to improve the Platform and to provide you the most user-friendly experience. All required Information are service dependent and wealthup.me may use the above said user Information to maintain, protect, and improve the Platform/ Services and/or for developing new services.

b) Furthermore, we may, however, use your email address and phone number without consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about updates to Platform Services, etc.).

c) Any Personal Information provided by you will not be considered as sensitive if it is freely available and/or accessible in the public domain. Further, any reviews, comments, messages, blogs posted/ uploaded/ conveyed/ communicated by users on the public sections of the Social Media sites or an Application Store (like the App Store or Play Store) becomes published content and is not considered Personal Information subject to this Privacy Policy.

d) In case you choose to decline to submit Personal Information on the Platform, we may not be able to provide certain services, if not all, on the Platform to you. We may make reasonable efforts to notify you of the same at the appropriate time. In any case, we will not be liable and/or responsible for the denial of certain services to you for lack of you providing the necessary Information.

e) When you register with the wealthup.me Account on the Platform, we may contact you from time to time about updating your Personal Information to provide such features that we believe may benefit/interest you.

f) In order to fulfil our legal obligations to prevent fraud and money laundering, we may obtain information about you from third party agencies ("Third Party Information"), including your financial history, court judgements and bankruptcies, from credit reference and fraud prevention agencies when you open a wealthup.me account and at any time when we feel it is necessary to prevent fraud and minimise our financial risks. Please refer to Paragraph 6 (Anti-Money Laundering Policy) of this Privacy Policy for further details.

2. Information Automatically Tracked while using the platform

a) The Platform also collects partial payment data and other information arising out of transactions made from cards, banks or while using other services through SMSes, after obtaining the User’s specific consent to allow the Platform to access the User’s SMS inbox.

b) The Platform accesses business messages that originate from alphanumeric senders. The Platform may read personal and OTP messages only for the purpose of providing better personalized Service. No personal SMSes or OTPs are backed up.

c) The collection of such information is only limited to the extent that such data is available in the relevant messages. wealthup.me may also record the identity of the product or service and the price or fee paid or payable in respect thereof.

d) We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We may use Google Analytics, among other analytics and marketing tools, to track user behaviour on our Platform to help us gain an understanding of our users’ demographics and interests.. These tools may collect and track app usage data and leverage user identifiable data for analytics and marketing purposes.

e) Our servers automatically collect limited information about your device’s connection to the Internet when you use the Platform. We automatically receive and log information from the Platform including but not limited to IP address, your device’s name, and your operating system. We may also collect log information from your device, including but not limited to your location, IP address, your device’s name, device’s serial number or unique identification number, your device operating system, and version, CPU speed, and connection speed etc.

3. SMS and Contact Permission

a) One of the major features of wealthup.me app is automatic tracking and splitting of your expenses. We track your expenses by reading your transactional and business SMS, even when the app is closed or not in use. The SMS is uploaded to our server to extract information including, the date of expense, merchant name and amount. These expenses are categorised and shown to you. We also run various algorithms on this information to provide you with additional insights and notifications to help you stay within budget. We also allow you to split your expenses with your contacts. The app also allows you to send them a message with the details of expenses to your contact to inform them. 

b) This information is uploaded on our server so that your details are synced and available on all our platforms across wealthup.me web app, Android app, iOS app and iPad app.

4. Link to third party sites

a) The Platform may include links to other websites/platforms. Such websites/platforms are governed by their respective privacy policies, which are beyond our control. Once you leave our servers, use of any information you provide on such Third Party websites/platforms are governed by the privacy policy of the operator of the websites/platforms you are visiting. That policy may differ from ours. If you cannot find the privacy policy of any of these websites/platforms via a link from the websites/platforms’s homepage, you should contact the websites/platforms directly for more information.

b) It is reiterated that wealthup.me, for the purposes of payments and settlements will direct user to our registered Payment and Settlement Merchant. We do not store any information regarding payment details, including but not limited to Internet Banking, Debit or Credit Card details. All such information is submitted to such registered Payment and Settlement Merchant and you are governed by the Terms and Conditions of Use and Privacy Policy of such merchant. wealthup.me shall not be liable in any case of any loss of data, including financial credentials and its data, on such Third Party vendors or merchants. In such event you will hold wealthup.me harmless and innocent and indemnify wealthup.me for all costs whatsoever.

5. Use and storage of Information

a) We use your Information for the following purposes:

  1. To operate and administer your wealthup.me account and to provide services that you have requested
  2. To carry out your instructions to make and/or receive payments and undertake transactions using our Services
  3. To allow you to participate in interactive features of the Platform;
  4. To notify you about changes to our service(s)
  5. To improve our internal customer training
  6. To comply with financial services regulations
  7. For financial and identity checks, fraud prevention checks, anti-money laundering and credit checks
  8. For customer service, including answering questions and responding to feedback and complaints
  9. To enhance the security of our Services
  10. To ensure that content on our Platform is presented in the most effective manner for you and for your device, and
  11. To provide you with information, products or services that you request from us or which we feel may interest you

b) Retention of Data: We are required under applicable laws to retain certain records for a certain period of time after closure of your wealthup.me account, which will include your personal data such as your name, contact details, customer number, phone numbers from your address book (contact upload) and transaction history, etc. ("Retained Data"). Other than the Retained Data, we will delete and destroy all Personal Information that we hold about you when you (or we) terminate your wealthup.me account. Under no circumstances, we store your payment credentials.

c) Please note that we will never ask you to disclose your personal or security details by e-mail. If you receive any e-mail purportedly from wealthup.me requesting your personal or security details, please do not respond to it (Such E-mail). Please forward any Such E-mail to us at support@wealthup.me and thereafter delete the e-mail immediately.

d) Contact upload is an optional feature that allows us to check which of your contacts in your device's address book are also our users. It also means we can update your wealthup.me contact list when your contacts who aren't using wealthup.me yet sign up later. We care about your privacy and we don't share your contact list with any other platform, even when they provide us with services.

When you use contact upload and grant wealthup.me access to your device address book, we will access and upload the phone numbers in your address book at regular time intervals, depending on various factors including how often a user uses wealthup.me. We don’t collect any of the other information that could appear in your device address book including names, email addresses, etc.

You can control the contact upload feature from your device-based settings. If you choose not to use Contact Upload, you can still use wealthup.me but certain functionality will be limited.

6. Disclosure of Information

a) We do not disclose your Information to any third parties other than the wealthup.me’s affiliates and the following:

  1. a prospective buyer of our business or a buyer of a substantial number of the shares in our business
  2. the police, other lawful enforcement body, regulatory body or Hon’ble Court if we are under a duty or required by law to disclose or share your personal data, or to protect the rights, property, or safety of ourselves or our group companies, our customers, or others
  3. Financial institutions with whom we partner to jointly provide better services, facilities or products to you. These financial institutions may only use your information for providing to you their services and market wealthup.me related products without requiring your further consent
  4. Third parties where you have expressed an interest in receiving information about their goods and/or services
  5. Third parties who referred you to us initially and to whom we owe a commission payment as a result of the referral. Where the commission payment is based on transaction volumes, numbers or types of transactions, we may share that information with that third party, but we will not disclose the full details of each of your transactions without your further written consent; and
  6. Third parties we may occasionally use to provide you with the services that you have requested. We require these third parties to not use your personal information for any other purpose.

b) We also use Information in aggregate form (so that no individual user is identified):

  1. To build up marketing profiles
  2. To aid strategic development
  3. To audit usage of the Platform

c) We reserve the right to disclose Information if required to do so by law or if we believe that it is necessary to do so to protect and defend the rights, property or personal safety of the Platform, or its users.

d) Personal Information: We will not rent or sell your personal information to others, nor will we share your personal information with independent third parties for marketing purposes. We use other companies, agents, or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, security, infrastructure, and IT services, to customize, personalize and optimize our service, to process payment transactions or other payment methods, to analyse and enhance data (including data about users' interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. The handling and use of information are governed by their individual privacy policies.

Below are categories of recipients of your personal data and some examples of the third parties in that category. If you would like more information on any of these categories or specific recipients, please contact us at support@wealthup.me:

  1. Cloud Service Providers ( Amazon Web Services and Firebase )
  2. Communication Services ( Sendgrid )
  3. Payment Processors ( Razorpay )
  4. Login Partners ( Google )
  5. Analytics ( Firebase )

7) Anti-Money Laundering Policy

a) In order to comply with anti-money laundering laws that exist in various jurisdictions we reserve the right to report suspicious transactions to Central, State, provincial or local authorities and law enforcement agencies within those jurisdictions. In exchange for us permitting you to participate in, use and access our Platform and/or Services, you hereby grant us the right to report any transactions which we deem suspicious, as determined solely by wealthup.me acting in its sole discretion. Examples of a suspicious transaction include but are not limited to use of funds suspected to be derived from illegal activities, any suspected intention to conceal or disguise funds derived from illegal activities, or suspicion that the involvement of our Platform and/or Services is in any manner intended to facilitate criminal activity. If for any reason we are of the belief or become aware of any transaction which we deem suspicious in nature, we may without prior notice or explanation to you take the following actions, which are in addition to all other rights and remedies available to us under this Privacy Policy, at law or in equity:

b) report such transaction to the applicable Central, State, provincial or local authorities and law enforcement agencies;

c) de-activate or terminate your wealthup.me account and Services forthwith; restrict you from registering a wealthup.me account on our Platform or with any of our affiliated Platforms/Business associates.

8. Communications

a) We may contact you via the e-mail address and phone number registered with your wealthup.me account. You may also receive system-generated transactional e-mails such as confirmations, notification of receipt of payments, notification of password changes etc. which are necessary for the proper operation and administration of your wealthup.me account. You expressly consent to receive such communications from us, irrespective of whether your phone number is registered on the National Do-Not-Call Registry or Do-Not-Disturb Registry.

b) As a wealthup.me account holder, you will occasionally receive information by e-mail from us, unless you have expressly chosen not to receive such communication, about products, services and special deals which we think will be of interest to you via our newsletter. You can change whether or not you wish to receive newsletters from us. However please note that you will still receive communication regarding your wealthup.me account such as transactional e-mails or other notifications affecting the operation of your wealthup.me account or our legal relationship.

9. Phishing

Phishing is the name given to attempts to steal personal details and financial account details from a Platform user. "Phishers" use fake or "spoof" emails to lead users to counterfeit websites where the user is tricked into entering their personal details, such as financial credentials, user-names and passwords. If you receive such an e-mail or are asked for your password by anyone claiming to work for us please forward the e-mail or report the incident by e-mail to us at support@wealthup.me.

10. User Choice

You may choose not to provide us with any Information while accessing the Platform. In such an event, you will not be able to access and use those portions of the Platform that require your Information.

11. Confidentiality and Security

a) Except as otherwise provided in this Privacy Policy, we will keep your Information private and will not share it with third parties, unless we believe in good faith that disclosure of your Information or any other information we collect about you is necessary to:

b) comply with Hon’ble Court’s order(s) or other legal process;

c) Protect the rights, property or safety of wealthup.me, its members or another party. Enforce our Conditions of Use or

d) Respond to claims that any posting or other content violates the rights of third parties

12. Information, Storage and Backup

We take a backup of your data on Platform on our Cloud database. This is done for the purpose of enabling users to get their data back in case their phone’s data becomes unusable, if the phone is lost, or the user moves to a new phone device. We also use this backup to provide useful insights and information related to their spends such as weekly / monthly spends, insights related to spend behaviour, etc., and to provide information related to user spends, patterns and user data in the form of aggregated and anonymised statistics on data such as user spends by category, date, time, bank balances, etc.

13. Information Security

a) We take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorised access to systems where we store personal data. All information gathered on the wealthup.me Platform is securely stored within the controlled database. Access to the servers is password-protected and is strictly limited. We use standard authentication using mobile no for establishing a secure connection. All the user data is transmitted via this secure connection, for other third party services we use authentication as requested by that third party service provider.

b) Although we make good faith efforts to store Information in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Information. If we become aware that your Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by law.

14. Updates/Changes

a) We may alter our privacy policy from time to time to incorporate necessary changes in technology, applicable laws or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Privacy Policy or the Conditions of Use. Any changes we make will be effective immediately.

b) Your use of the Platform and/or Services after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform you via electronic mail. In any case, you are advised to review this Privacy Policy periodically to ensure that you are aware of the latest version here https://www.wealthup.me/privacy.

15. Your rights

You have a legal right to a copy of any Information about you held by us. You also have a right to correct any errors in that Information. As mentioned above, you have a right to request that we cease to use your Information for direct marketing purposes. For exercising this right, please feel free to contact us at support@wealthup.me.

16. Restrictions of Liability

a) We make no claims, promises or guarantees about the accuracy, completeness, or adequacy of the contents of Platform and expressly disclaim liability for errors and omissions in the contents of the Platform.

b) No warranty of any kind, implied, expressed or statutory, including but not limited to the warranties of non-infringement of third party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus, is given with respect to the contents of the Platform or its hyperlinks to other internet resources.

c) No warranty of any kind, implied, expressed or statutory, including but not limited to the warranties of non-infringement of third party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus, is given with respect to the contents of the Platform or its hyperlinks to other internet resources.

17. Questions/Grievance Redressal

In the event you have any grievance relating to the Privacy Policy or any other information relating to the use of Information/data, you may contact us at support@wealthup.me.