Kiwi: A revolutionary virtual credit card

Privacy Policy

Last updated on: [15th April, 2024]

We are committed to keep your data secure, your private information private and being transparent about our practices. We adhere to the best practices to secure information collected from You.

GOKIWI TECH PRIVATE LIMITED, having its registered office at A-101, Tower 5, Plot 8P-T, T-5, Diero, Lodha New Cuffe Parade, Antop Hill, Mumbai – 400037 and its corporate office at 1st floor, 1515 Urban, 19th Main Road nearby Hustlehub, Vanganahalli, Bengaluru Urban, Karnataka – 560034 (“Company” or “we” or “us” or "our"), is the owner of the website domain at https://gokiwi.in/ and https://kiwicard.co.in/ and mobile application titled “Kiwi: Rupay Credit Card on UPI” available on the Google Play Store/Apple Play Store at [ https://play.google.com/store/apps/details?id=in.gokiwi.kiwitpap&source=gokiwi and https://apps.apple.com/in/app/kiwi-rupay-credit-card-on-upi/id6449386307?source=gokiwi] , respectively (collectively referred as “Platform”) and any service availed by Users (hereinafter referred to as “you”, “your” or “User”) through the Platform is conditioned upon your acceptance of the terms and conditions contained in Terms of Service as available on Platform and this privacy policy (“Privacy Policy”). This Privacy Policy shall apply to any person who visits, browses, uses or accesses the Platform or use any Services on the Platform.

This Privacy Policy has been drafted and is published in compliance with The Information Technology Act, 2000, and applicable amendments, rules, regulations and guidelines enacted thereunder from time to time (“IT Act”) with specific mention of regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive personal information) Rules, 2011 (“SPDI Rules”) and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2023, and any other national and state laws which relate the processing of data. This Privacy Policy is an electronic record in terms of the IT Act and this electronic record is generated by a computer system and does not require any physical or digital signatures. Any new features and/or services that are added to our current Services at any point in the future shall also be subject to the terms set out in this Privacy Policy along with any other future relevant legislations to be incorporated as per the laws of the land.

We use your data to provide you Services and to improve the Platform as well as your experience of our Platform. By using the Platform, you agree to the collection and use of information in accordance with this Privacy Policy.

INTRODUCTION AND APPLICABILITY OF THE PRIVACY POLICY
1. We are strongly committed to respecting your online privacy and recognize the need for appropriate protection and management of any personal information collected, collated and/or processed by us.
2. The purpose of this Privacy Policy is to ensure that there is an intact charter that governs the collection, usage and protection of any personal and/or sensitive data collected by us. This Policy informs our Users/ visitors of our procedures regarding collection, usage, storage, processing, disclosure, sharing and protection of any Personal Data or Sensitive Personal Data obtained by us through the Platform.
3. Any reference made to Privacy Policy in this document shall mean and refer to the latest version of the Privacy Policy.
DISCLAIMER
Please be advised that any Information (as defined herein below) procured by us, shall be:
1. processed fairly and lawfully for rendering the Services (as defined in the Terms of Service);
2. obtained only for specified and lawful purposes, and not be used in any manner which is against the law or policy in force in India (“Applicable Law”);
3. adequate, relevant and not excessive in relation to the purpose for which it is required;
4. able to be reviewed by the User, from time to time and updated-if need arises; and
5. not kept longer than for the time which it is required or the purpose for which it is required or as required by the applicable law.
1. WE SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE SUSTAINED BY REASON OF ANY DISCLOSURE (INADVERTENT OR OTHERWISE) OF ANY OF YOUR INFORMATION AND DATA, IF THE SAME IS EITHER (A) REQUIRED FOR SHARING YOUR INFORMATION FOR LEGITIMATE PURPOSES; OR (B) WAS EFFECTED THROUGH NO FAULT, ACT, OR OMISSION OF THE COMPANY OR (C) WAS EFFECTED IN OFFERING OF OUR LAWFUL SERVICES OR (D) IS ATTRIBUTABLE TO THE NEGLIGENCE OF THE USER.
2. BY USING THE PLATFORM OR SERVICES, YOU EXPLICITLY ACCEPT, WITHOUT LIMITATION OR QUALIFICATION, THE COLLECTION, USE AND TRANSFER OF THE INFORMATION/ DATA IN THE MANNER DESCRIBED HEREIN.
3. PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT AFFECTS YOUR RIGHTS AND LIABILITIES UNDER LAW.
Your consent
1. Please note that by providing the Information (as defined herein below), you provide your consent and authorize us to collect, use or disclose such Information for the business and research purposes and as stated in this Policy, and as permitted or required by applicable law. Moreover, you understand and hereby consent that this Information may be disclosed/ shared to any third party for the purpose of assessing or evaluating whether the Services can be provided to you, providing Services through the Platform or to any third-party providers for rendering Services (as defined in the Terms of Service), any jointly developed or marketed services, payment processing, order fulfilment, customer services, fraud management services, data analysis, information technology services and such other services which enable us to provide Services through the Platform.
2. This Privacy Policy shall be enforceable against you in the same manner as any other written agreement. By visiting or accessing the Platform and voluntarily providing us with Information (including Personal Data), you are consenting to our use of the Information, in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you may choose to not provide us with any Personal Data and/or Sensitive Personal Data. Under such circumstance, we may be unable to render Services.
3. Such an intimation to withdraw your consent can be sent to service@gokiwi.in. You understand that withdrawal of consent shall lead to suspension of your GoKiwi account as we shall not be able to provide the Services to you.
TYPES OF DATA COLLECTED
We collect several different types of information for various purposes to provide and improve our Platform to you.
1. “Sensitive Personal Data” means and includes information relating to - (i) name; (ii) phone number / mobile number; (iii) name of father/ mother; (iv) addresses such as residential address and official address; (v) employment details; (vi) education details; (vii) government ID cards; (vii) financial information such as bank account or credit card or debit card or other payment instrument details; (viii) sexual orientation;; and (ix) any detail relating to the above-mentioned points as provided to us for using the Platform
2. “Personal Data”, means and includes any Information that relates to a natural person through which an individual is identified, such as the name, contact details, email address, gender, age or any other relevant material provided by a User, including but not limited to information gathered through availing Services, communications with the instructors. It shall also cover information of User’s care person details (name, age, gender, mobile number, relationship with the User).
3. “Transaction Information” means information that is contained in text messages (that is, SMS) sent by providers of services and/or products (including but not limited to financial institutions, mobile carriers and utility companies) to your mobile telephone number(s) in connection with one or more transactions across multiple financial accounts (including purchase, payments, billing information and service notifications related thereto). Without limitation, Transaction Information includes:
4. “Technical Information” means and includes any Information gathered through various technologies that may employ cookies, web beacons, or similar technologies to automatically record certain information from your device through which you use the Platform. This technical information may include your Internet Protocol (IP) address, device or browser type, Internet service provider (ISP), referring or exit pages, clickstream data, operating system, hardware model, operating system version, unique device identifiers, and mobile network. This data includes usage information and user statistics.
5. “Locational Information” shall mean and include the information obtained through GPS or other means, such as the geographical location of the User.
6. “Non-Personal Information” means and includes any information that does not reveal your specific identity, such as, browser information, information collected through Cookies (as defined below), pixel tags and other technologies, demographic information, etc. As is true with most websites, our Company gathers some information automatically when you visit the Platform. When you use the Platform, we may collect certain information about your computer or mobile to facilitate, evaluate and verify your use of the Platform. For example, we may store environmental variables, such as browser type, operating system, speed of the central processing unit (CPU), referring or exit web pages, click patterns and the internet protocol (IP) address of your computer. This information is generally collected in aggregate form, without identifying any user individually.
  The above-mentioned information shall be collectively referred to as “Information”.

PURPOSE OF COLLECTION AND USAGE OF DATA
1. The Information collected by us shall be used for availing our Platform and utilised for other functions including but not limited to:
  1. to render Services;
  2. to evaluate the quality and competence of our personnel;
  3. to resolve any complaints, you may have and ensure that you receive the highest quality of Services;
  4. notifying you about changes to our Platform;
  5. providing analysis or valuable information so that we can improve the Platform;
  6. monitoring and maintaining the usage of the Platform;
  7. sending out system updates on the booked services;
  8. detecting, preventing and addressing technical issues;
  9. detecting or preventing fraud, or any other form of risks;
  10. sending out payment/ collections reminders;
  11. analysing usage patterns;
  12. improving user experience;
  13. re-marketing campaigns (SMS, WhatsApp messages, emails, PN campaigns);
  14. targeted marketing campaigns, periodic follow-ups;
  15. notifying you about new services and features added to or introduced via the Platform;
  16. evaluation/ assessment for the purposes of providing Services.
2. Business or Research Purposes: The Information saved and except Personal Information, is used for business or research purposes, including improving and customizing the Platform for ease of use and the services offered by us. We may archive this information to use it for future communications for providing updates and/or surveys.
3. Aggregating Information / Anonymized data: We may aggregate Information and analyse it in a manner to further accentuate the level of Services that we offer to our customers. This Information includes average number of Users of the Platform, the average clicks of the Services/, the features used, the response rate, etc. and other such statistics regarding groups or individuals.
Connecting your email account and granting email access:
By clicking on the authentication email sent by the Company to your registered email address, You are explicitly consenting to connect/integrate your email account(s) with the Platform. You will be asked expressly in each case whether you want to connect your email address with the Platform. You can also choose to enable our access to one or more of your email accounts by connecting such account(s) with your account on the Platform.
Upon integrating your email with the Platform, we may upload your image on our platform for app functionality, and you hereby give your consent for the same.
The data obtained by this integration will be used by the Company are for providing the Services, improving your experience of the features of the Platform, and checking your credit rating. The Company agrees and acknowledges that it shall not use or transfer any data or information received from the integration of the email addresses with the Platform to third parties for serving ads, including retargeting, personalized, or interest-based advertising.
By integrating your email account with the Company, You authorize us to read access the email account to collect certain financial information such as:
1. credit card bill specifics such as total amount due, minimum amount due and due date, and other financial and transactional information;
2. details regarding other bills such as utility bills;
3. other financial details.
We restrict our email reading to those related to financial services, such as credit card rating, credit card statements, bank statements, biller details, etc., and we do not access any personal emails.
We encourage you to review the information prior to giving your consent for integration of the email addresses with the account on the Platform. You may at any time opt to de-link your email addresses connected with the account opened on the Platform by managing these connections with the options provided on the Platform.
DISCLOSURE AND SHARING OF INFORMATION:
We do not rent, sell or disclose or share any information that we collect from you, with third parties, save and except in order to provide you with the Services. Any such disclosure, if made, shall be in accordance to this Privacy Policy and as per the procedure prescribed by law and in compliance with our legal obligations. We may share your Information in circumstances and for the purposes as specified hereunder:
1. We may share the information to the third-party service providers/ vendors, to provide you with the Services or to improve the Services or to evaluate any possible business arrangement with third parties which may enhance the quality of Services being provided or to evaluate whether Services may be provided to you. This may include but not be limited to Lenders (as defined in the Terms), storage providers, data analytics providers, consultants, lawyers, and auditors.
2. When compelled by law, we may disclose any Information (including Personal Data and Sensitive Personal Data) provided by you on the Platform as may be deemed to be necessary or appropriate:
  1. under applicable law, including laws outside your country of residence;
  2. to comply with legal process;
  3. to respond to requests from public, regulatory, legal enforcement and government authorities including public and government authorities outside your country of residence;
  4. to allow us to comply with any judgement or decree or order issued under any law for the time being in force in India, or any judgment or order relating to claims of a contractual or civil nature under any law for the time being in force outside India; v. to protect our operations or those of any of our affiliates;
  5. to protect our operations or those of any of our affiliates;
  6. to protect our rights, privacy, safety or property, and/that of our affiliates, you or others;
  7. to allow us to pursue available remedies or limit the damages that we may sustain; or
  8. to protect against legal liability;
  9. to protect the personal safety of Users of the Platform;
  10. to prevent or investigate possible wrongdoing in connection with the Platform.
3. Merger or Acquisition: We may share Information upon merger or acquisition of Company with another company, which shall automatically acquire the rights and obligations mentioned in the Privacy Policy. We shall transmit and transfer the Information upon acquisition or merger of Company with another company.
4. With our service providers: We may share Information (including Personal Data and Sensitive Personal Data) with other service providers on a need-to-know basis, subject to obligations of confidentiality for provision of Services. We hereby clarify that Company works with institutions, vendors, partners, advertisers, and other service providers, including (but not limited) to those who provide services such as credit based services to our Users, contact Information verification, website hosting, data analysis, providing infrastructure, information technology services, auditing services and other similar services, in different industries and categories of business by virtue of lawful contracts instituted between such third parties and Company to improve our services. Accordingly, we may share your Information with such service provider as reasonably necessary to provide you with Services.
5. Employees /Agents of Company: We follow a strict confidentiality policy with regard to disclosure of confidential information to our employees or other personnel. There may be situations, where we may disclose the confidential information only to those of our employees and other personnel on a need to know basis. Any breach of confidential information by the employees, personnel within the Company is dealt with stringently by us.
6. Business Partners: We may share your Information with our present or future business partners to either provide you Services or to enhance the quality of our Services.
7. We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.
8. Except for the Information disclosed pursuant to sub-clause (a) to (f) of Clause 7.1 above, Company may share Information only if you authorize us to do so.
TRANSFER OF DATA
1. Your Information may be transferred to, and maintained on, computers located in Mumbai India, and will be governed by the Indian data laws.
2. If you are located outside India and choose to provide information to us, please note that we may transfer the data to India to process the Information.
3. Your consent to this Privacy Policy followed by your submission of such information represents your unconditional agreement to that transfer or use.
4. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your data will take place to an organization or a country unless there are adequate controls in place including the security of your data.
YOUR RIGHTS
1. You can always choose not to provide the requested information to us, it may however result in You not availing certain features if, or the entirety, of our Services.
2. You retain several rights in relation to your Personal Data as provided under applicable law. These may include the rights to:
  1. access, confirm, and review Personal Data you may have provided;
  2. correct Personal Information that may be inaccurate or irrelevant;
  3. deletion and erasure of your Personal Data from the publicly available pages of the Platform;
  4. receive Personal Information we hold about you in a portable format;
  5. object to or restrict any form of processing you may not be comfortable with.
3. In order to exercise these rights, please contact us at the email address provided in Clause 3.3 above.
4. If you want to withdraw your consent or raise any objection to the use of your information for receiving any direct marketing information to which you previously opted-in, you can do so by contacting us at the above-mentioned email address. If you withdraw/object your consent, our use of your information before you withdrew/objected shall continue to be lawful.
APPLICATIONS USED
1. You may be availing our services for using third party mobile applications, which are not operated by us. We strongly advise you to review the privacy policy of every mobile application which you may use.
2. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party mobile applications or services.
CHILDREN’S PRIVACY
Our Platform and Services are not meant for use by children and we knowingly do not collect or solicit Personal Information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected Information from/of a person under the age of 18, we shall take steps to remove such Information from our servers as quickly as possible. If you believe that a person under age 18 may have provided us with Personal Information, please write to us at the email address - service@gokiwi.in.
CONTROL THE COLLECTION OR USE OF THE INFORMATION
Our Platform and Services are not meant for use by children and we knowingly do not collect or solicit Personal Information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected Information from/of a person under the age of 18, we shall take steps to remove such Information from our servers as quickly as possible. If you believe that a person under age 18 may have provided us with Personal Information, please write to us at the email address - service@gokiwi.in.
RETENTION OF INFORMATION
All Information provided by you, save and except upon withdrawal or termination, shall be retained in locations outside the direct control of Company (for instance, on servers or databases co-locates with hosting providers). We will delete Information based on a request received from you within a reasonable period and latest within 180 (one hundred and eighty days) of receiving a deletion request. However, we may retain such portion of Information and for such periods as may be required under Applicable Law. Notwithstanding anything contained herein, Company may retain data after account deletion for reasons including but limited to the following purposes: If there is an unresolved issue relating to your account, or an unresolved claim or dispute; If we are required to by applicable law; and/or in aggregated and/or anonymized form; or Company may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing Users' safety and security.
COOKIES AND OTHER TRACKING TECHNOLOGIES
Our Platform may utilize “cookies” and other Technical Information. “Cookies” are a small text file consisting of alphanumeric numbers used to collect the Information about Platform activity. The Technical Information helps us analyse web traffic and helps you by customizing the Platform to your preferences. Cookies in no way gives us access to your computer or mobile device. In relation to Cookies, you can deny access to the installation of the Cookies by modifying the settings on your web browser, however, this may prevent you from taking full advantage of the Platform. Our use of Cookies and Technical Information allows us to improve Platform and your experience of Platform and Services. We may also analyse Technical Information that does not contain Personal Information for trends and statistics.
THIRD PARTY SERVICES
We may use your Information to send you promotional Information about third parties which, we think you may find interesting, if you tell us that you wish this to happen. We shall not be responsible for any disclosure of Information due to unauthorized third-party access or other acts of third parties or acts or omissions beyond our reasonable control and you agree that you will not hold us responsible for any breach of security unless such breach has been caused as a direct result of our negligence or wilful default.
Once you leave the Platform, we are not liable for any use/ storage/ processing/ collection of your information obtained by any third-party websites or payment facilitators or provided by you to these third-parties or payment facilitators. Such entities and their respective websites/platforms may be governed by their own “Privacy Policy” and “Terms of Service”, which are beyond our control.
DATA SECURITY
You agree and accept that your Information may be stored in third-party cloud service infrastructure providers. While all reasonable attempts have been taken from our end to ensure the safe and secure storage of your data, we shall not be liable for any data breach on the part of the third-party cloud service infrastructure provider that was beyond our control. In addition to the security measures put in place by the third-party cloud service infrastructure provider for safe and secure storage of your Information, we use certain physical, managerial, technical or operational safeguards as per industry standards and established best practices to protect the Information we collect. We use reasonable security practices and procedures and use secure servers as mandated under applicable laws for the protection of your Information. We review our Information collection, storage, and processing practices, including physical security measures to guard against unauthorized access to systems. However, as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that the Information you supply will not be intercepted while being transmitted to us over the internet. You accept the inherent security implications of data transmission over the internet and the internet cannot always be guaranteed as completely secure. Therefore, your use of the Platform will be at your own risk. If you have any concerns, please feel free to contact us by emailing us at - service@gokiwi.in.
Please note that you alone will have the knowledge of your OTP. It is important for you to protect against any unauthorized access to your OTP, your contact details and your mobile phone. As a security measure, please ensure logging off from the Platform when finished. We do not undertake any liability for any unauthorized use of your account.
CHANGES AND UPDATES TO POLICY
We may modify or revise the Privacy Policy from time to time and shall accordingly notify you of any changes to the Privacy Policy by posting the revised Privacy Policy on the Platform with an updated date of revision. We shall endeavour to review, revise, update, modify, amend or correct the Privacy Policy on a regular and routine basis, especially whenever a significant update is made to the technology employed by us. You must periodically review the Privacy Policy for the latest information on our privacy practices. In the event you continue to use the Platform and our services after any update in the Privacy Policy, your use of the Platform shall be automatically subject to such updated privacy policy. Your continued usage of Services or access of the Platform post any amendment would deem to mean that you accept and agree to the revised Privacy Policy. Further, we retain the right at any time to deny or suspend access to all, or any part of, the service to anyone who we reasonably believe has violated any provision of this Privacy Policy.
DISCREPANCIES AND GRIEVANCES WITH COMPANY
In case of any discrepancy or grievance with respect to all or any Information shared with Company, please feel free to contact our Grievance Officer:
Attention: Anthony Mathew S A
Email ID: greviance@gokiwi.in
Address: Opp BMTC Bus Depot Sector-1, Ground Floor, 1608, urban vault hsr layout, 7th cross, Agrahara Village, Bengaluru, Bengaluru Urban, Karnataka, 560102
We assure you that we shall ensure implementation of the Privacy Policy and shall make the Privacy Policy available to Users. We will acknowledge each grievance that is received within 24 hours and put our best efforts to redress the grievances of the User expeditiously within fifteen (15) days from the date of receipt of the grievance. The User agrees and acknowledges that the Company shall address and attempt to resolve the complaint received in accordance with the standard policies and procedures adopted by the Company, the User’s disapproval/discontent with the outcome/mode of redressal shall not be deemed to mean non-redressal of the grievance by the Company. Any suggestions by Company regarding use of the Service shall not be construed as a warranty.
Please feel free to reach out to us by e-mail at service@gokiwi.in in case of any concerns, grievances, or questions relating to our privacy or data related practices.
MISCELLANEOUS
THE INVALIDITY OR UNENFORCEABILITY OF ANY PART OF THIS PRIVACY POLICY SHALL NOT PREJUDICE OR AFFECT THE VALIDITY OR ENFORCEABILITY OF THE REMAINDER OF THIS PRIVACY POLICY. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION OTHER THAN THE INFORMATION COLLECTED BY US THROUGH THE PLATFORM. THIS PRIVACY POLICY SHALL BE INAPPLICABLE TO ANY UNSOLICITED INFORMATION YOU PROVIDE US THROUGH THE PLATFORM OR THROUGH ANY OTHER MEANS. ALL UNSOLICITED INFORMATION SHALL BE DEEMED TO BE NON-CONFIDENTIAL AND WE SHALL BE FREE TO USE AND/ OR DISCLOSE SUCH UNSOLICITED INFORMATION WITHOUT ANY LIMITATIONS. THE RIGHTS AND REMEDIES AVAILABLE UNDER THIS POLICY MAY BE EXERCISED AS OFTEN AS NECESSARY AND ARE CUMULATIVE AND NOT EXCLUSIVE OF RIGHTS OR REMEDIES PROVIDED BY LAW. RIGHTS UNDER THIS POLICY MAY BE WAIVED ONLY IN WRITING. DELAY IN EXERCISING OR NON-EXERCISE OF ANY SUCH RIGHT OR REMEDY DOES NOT CONSTITUTE A WAIVER OF THAT RIGHT OR REMEDY, OR ANY OTHER RIGHT OR REMEDY.
GOVERNING LAWS AND JURISDICTION
This Privacy Policy, the Platform, the Services and the use of it is governed by the laws of India and the courts in [Bangalore] in India shall have exclusive jurisdiction over any disputes connected to our Privacy Policy, Platform or the Services and your use of it.
YOUR ACCEPTANCE OF THESE TERMS
BY USING OR VISITING THIS PLATFORM, YOU SIGNIFY YOUR AGREEMENT OF THIS POLICY. IF YOU DO NOT AGREE TO ANY OF THESE TERMS, PLEASE DO NOT USE OUR PLATFORM OR SERVICES.