Privacy Policy

Effective Date: January 2025
Last Updated: January 2025

YOUR CONSENT: By downloading, installing, accessing, or using the Laddoo mobile application ("App"), you expressly consent to the collection, use, storage, disclosure, and processing of your personal information as described in this Privacy Policy. If you do not agree with this Privacy Policy, you must immediately discontinue use of the App and delete it from your device.

1. INTRODUCTION AND SCOPE

1.1 About This Policy: This Privacy Policy ("Policy") describes how Laddoo App ("Company," "we," "us," or "our") collects, uses, stores, processes, discloses, and protects your personal information when you use our mobile application and services.

1.2 Applicability: This Policy applies to all users of the Laddoo App, including:

Registered users who have created an account;
Non-registered users who browse or access the App;
Users who conduct transactions through the App;
Users who interact with our customer support or services;

1.3 Binding Nature: This Privacy Policy is legally binding and forms an integral part of our Terms and Conditions. Your use of the App constitutes your acceptance of this Policy.

1.4 Updates and Modifications: We reserve the right to update, modify, or change this Privacy Policy at any time. We will notify you of material changes through the App or via email. Continued use of the App after such modifications constitutes your acceptance of the updated Privacy Policy.

2. INFORMATION WE COLLECT

We collect various types of information to provide, maintain, improve, and protect our Services. The information we collect falls into the following categories:

2.1 Personal Identification Information

Information that can be used to identify you individually:

Mobile Phone Number: Primary identifier for account creation and verification (mandatory);
Full Name: For account personalization and KYC purposes (mandatory for withdrawals);
Email Address: For communications and account recovery (optional);
Date of Birth: For age verification and compliance purposes;
Government-Issued ID: For KYC verification when withdrawing cashback (as required by law);

2.2 Financial and Transaction Information

Bank Account Details: For cashback withdrawal processing (account number, IFSC code, account holder name);
Payment Method Information: Partial payment information (last 4 digits of cards, UPI ID) - full payment details are processed by third-party payment gateways and not stored by us;
Transaction History: Complete record of all recharge transactions, amounts, dates, mobile numbers recharged, and transaction statuses;
Cashback Information: Cashback earned, used, withdrawn, and wallet balance;
Refund Information: Refund requests, approvals, rejections, and processing status;

2.3 Device and Technical Information

Information automatically collected when you use the App:

Device Information: Device model, manufacturer, operating system version, unique device identifiers (IMEI, Android ID, Advertising ID);
App Usage Data: Features accessed, screens viewed, time spent on app, interaction patterns, frequency of use;
Location Information: Approximate location based on IP address (precise location only if you grant permission);
Network Information: Mobile carrier, network type (Wi-Fi, 4G, 5G), IP address, network status;
Log Data: Crash reports, error logs, diagnostic information, performance data, timestamps;
Cookies and Similar Technologies: Session tokens, authentication tokens, preferences;

2.4 Communications and Support Data

Customer Support Communications: Chat messages, emails, phone call recordings (with notice), support tickets, complaints, feedback;
Survey Responses: Feedback, ratings, reviews, suggestions;
Marketing Communications: Preferences for promotional communications;

2.5 Social Media and Third-Party Information

If you choose to link social media accounts, we may collect profile information such as name, email, profile picture;
Information from third-party services you choose to connect with the App;

2.6 Inferred and Derived Information

User Preferences: Preferred recharge amounts, frequently recharged numbers, operator preferences;
Behavioral Patterns: Usage patterns, transaction patterns, engagement metrics;
Risk Assessment Data: Fraud detection signals, security risk scores;

3. HOW WE COLLECT INFORMATION

3.1 Information You Provide Directly:

When you register and create an account;
When you complete your profile;
When you initiate recharge transactions;
When you add bank account details for withdrawals;
When you contact customer support;
When you participate in surveys or promotions;
When you provide feedback or reviews;

3.2 Information Collected Automatically:

Through cookies, pixels, and similar tracking technologies;
Through device sensors and operating system permissions;
Through App analytics and monitoring tools;
Through server logs and databases;

3.3 Information from Third Parties:

From payment gateways regarding transaction status;
From Telecom Operators regarding recharge confirmation;
From fraud prevention and security service providers;
From social media platforms (if you choose to link accounts);
From publicly available sources for verification purposes;

4. HOW WE USE YOUR INFORMATION

We use the collected information for the following purposes:

4.1 Service Provision and Transaction Processing

To create, maintain, and manage your account;
To process mobile recharge transactions;
To credit cashback to your wallet;
To process cashback withdrawals to your bank account;
To verify your identity and prevent unauthorized access;
To provide customer support and resolve issues;
To send transaction confirmations and receipts;

4.2 Communication and Notifications

To send important service-related notifications (transaction confirmations, account updates);
To send promotional offers, deals, and marketing communications (with your consent);
To send push notifications about app features and updates (with your permission);
To respond to your inquiries and support requests;
To conduct surveys and gather feedback;

4.3 Improvement and Personalization

To analyze app usage patterns and improve user experience;
To personalize content, features, and recommendations;
To develop new features and services;
To conduct research and analytics;
To optimize app performance and fix technical issues;
To remember your preferences and settings;

4.4 Security and Fraud Prevention

To detect, prevent, and investigate fraudulent transactions;
To identify and prevent security threats and unauthorized access;
To monitor for suspicious activity and policy violations;
To verify the authenticity of transactions;
To maintain the security and integrity of our systems;
To comply with anti-money laundering (AML) requirements;

4.5 Legal and Regulatory Compliance

To comply with applicable laws, regulations, and legal processes;
To respond to lawful requests from government authorities;
To enforce our Terms and Conditions and other policies;
To protect our legal rights and interests;
To comply with KYC (Know Your Customer) requirements;
To maintain records as required by law;

4.6 Business Operations

To manage business relationships with partners and service providers;
To process payments and manage financial operations;
To conduct internal audits and maintain business records;
To facilitate business transfers, mergers, or acquisitions;

5. INFORMATION SHARING AND DISCLOSURE

OUR COMMITMENT: We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We only share your information in the limited circumstances described below.

5.1 Service Providers and Business Partners

We share information with trusted third-party service providers who assist us in operating the App:

Payment Gateways: To process recharge payments and cashback withdrawals (e.g., Razorpay, PayU, Paytm);
Telecom Operators: To process mobile recharge requests (Airtel, Jio, Vi, BSNL, etc.);
Cloud Service Providers: To host and store data securely (e.g., AWS, Google Cloud);
Analytics Providers: To analyze app usage and performance (e.g., Google Analytics, Firebase);
Customer Support Tools: To provide customer service (e.g., Zendesk, Freshdesk);
Fraud Detection Services: To identify and prevent fraudulent activities;
Marketing and Communication Platforms: To send notifications and promotional messages (with your consent);

These service providers are contractually obligated to maintain confidentiality and use your information only for the purposes we specify.

5.2 Legal and Regulatory Requirements

We may disclose your information when required by law or to protect our rights:

In response to court orders, subpoenas, or other legal processes;
To comply with regulatory requirements and government requests;
To law enforcement agencies investigating illegal activities;
To tax authorities as required by taxation laws;
To prevent fraud, security threats, or illegal activities;
To protect the rights, property, and safety of our company, users, or public;
To enforce our Terms and Conditions and other agreements;

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred to the successor entity. You will be notified of any such transfer and any choices you may have.

5.4 With Your Consent

We may share your information with third parties when you explicitly provide consent, such as:

Linking social media accounts;
Participating in partner promotions;
Sharing information with specific third-party services you choose;

5.5 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot be used to identify you individually for research, analytics, marketing, or other business purposes.

6. DATA SECURITY MEASURES

We implement industry-standard security measures to protect your personal information:

6.1 Technical Security Measures

Encryption: All data transmission is encrypted using SSL/TLS protocols; sensitive data is encrypted at rest;
Secure Servers: Data is stored on secure servers with firewalls and intrusion detection systems;
Access Controls: Role-based access controls limiting employee access to personal information;
Authentication: Multi-factor authentication for sensitive operations;
Regular Security Audits: Periodic security assessments and penetration testing;
Secure Payment Processing: PCI-DSS compliant payment processing through certified gateways;

6.2 Organizational Security Measures

Employee confidentiality agreements and data protection training;
Strict data handling policies and procedures;
Regular security awareness programs;
Incident response and data breach notification procedures;

6.3 Limitations

            IMPORTANT: While we implement robust security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information. You are responsible for maintaining the confidentiality of your account credentials.
        

7. DATA RETENTION

7.1 Retention Period: We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

7.2 Specific Retention Periods:

Account Information: Retained while your account is active and for 7 years after account closure (for legal compliance);
Transaction Records: Retained for 7 years from transaction date (as required by financial regulations);
KYC Documents: Retained for 7 years after last transaction (as per RBI guidelines);
Communication Records: Retained for 3 years for quality assurance and dispute resolution;
Log Data: Retained for 90 days unless required for fraud investigation or legal purposes;

7.3 Deletion: Upon expiry of retention period, personal information will be securely deleted or anonymized unless retention is required for legal, regulatory, or legitimate business purposes.

8. YOUR RIGHTS AND CHOICES

You have the following rights regarding your personal information:

8.1 Access Rights

Right to Access: Request access to your personal information we hold;
Right to Know: Request information about how we collect, use, and share your data;
Data Portability: Request a copy of your data in a portable format;

8.2 Correction and Update Rights

Right to Correct: Request correction of inaccurate or incomplete information;
Self-Service: Update your profile information directly through the App;

8.3 Deletion Rights

Right to Delete: Request deletion of your personal information, subject to legal retention requirements;
Account Deletion: Request permanent deletion of your account through our Account Deletion Request Page;
Limitations: We may retain certain information as required by law or for legitimate business purposes;

8.4 Communication Preferences

Marketing Opt-Out: Unsubscribe from promotional emails and marketing communications;
Push Notifications: Disable push notifications through device settings;
SMS Opt-Out: Opt out of promotional SMS by replying "STOP";
Note: You cannot opt out of essential service-related communications (transaction confirmations, security alerts);

8.5 Consent Withdrawal

Right to Withdraw Consent: Withdraw consent for data processing where consent was the legal basis;
Effect: Withdrawal does not affect the lawfulness of processing before withdrawal;
Consequences: May result in inability to provide certain services;

8.6 How to Exercise Your Rights

To exercise any of these rights, contact us at:

Email: [email protected]
Phone: +91 7726828026
In-App: Settings → Privacy → Data Rights Request

We will respond to your request within 30 days. We may request verification of your identity before processing requests.

9. COOKIES AND TRACKING TECHNOLOGIES

9.1 Types of Technologies Used:

Cookies: Small text files stored on your device for authentication and preferences;
Session Tokens: Temporary identifiers for maintaining logged-in sessions;
Analytics Tools: Third-party analytics to understand app usage (Google Analytics, Firebase Analytics);
Advertising IDs: Device advertising identifiers for personalized content (with your consent);

9.2 Purpose:

To remember your preferences and settings;
To authenticate and maintain your logged-in session;
To analyze app usage and improve user experience;
To provide personalized content and recommendations;
To measure the effectiveness of marketing campaigns;

9.3 Managing Cookies and Tracking:

You can reset your advertising ID through device settings;
You can disable analytics tracking through App settings;
Disabling certain tracking may affect app functionality;

10. THIRD-PARTY SERVICES AND LINKS

10.1 Our App may contain links to third-party websites, services, or integrations (e.g., payment gateways, social media platforms).

10.2 We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

10.3 Third-party services have their own terms and privacy policies which govern their collection and use of your information.

11. CHILDREN'S PRIVACY

11.1 Age Restriction: Our Services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18.

11.2 Parental Consent: If we become aware that we have collected information from a child under 18 without parental consent, we will take steps to delete such information immediately.

11.3 Parental Rights: If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at [email protected].

12. INTERNATIONAL DATA TRANSFERS

12.1 Your information may be transferred to, stored, and processed in countries other than India, including countries that may have different data protection laws.

12.2 We ensure that such transfers comply with applicable data protection laws and implement appropriate safeguards, including:

Standard contractual clauses with service providers;
Ensuring service providers maintain adequate data protection standards;
Obtaining your explicit consent where required;

13. CHANGES TO THIS PRIVACY POLICY

13.1 Modification Rights: We reserve the right to update, modify, or change this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations.

13.2 Notification: We will notify you of material changes through:

In-app notifications;
Email notifications to your registered email;
Push notifications;
Prominent notice on the App;

13.3 Effective Date: Changes become effective immediately upon posting unless otherwise stated. Continued use of the App after changes constitutes acceptance of the updated Privacy Policy.

13.4 Review: We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

14. DATA BREACH NOTIFICATION

14.1 In the event of a data breach that compromises your personal information, we will:

Investigate the breach promptly and thoroughly;
Notify affected users within 72 hours of discovering the breach (as required by law);
Provide details about the nature of the breach and steps we are taking;
Advise you on steps you can take to protect yourself;
Report the breach to relevant regulatory authorities as required by law;

15. CONTACT INFORMATION AND GRIEVANCE REDRESSAL

15.1 Privacy Concerns: If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

Data Protection Officer - Laddoo App

Email: [email protected]

Phone: +91 7726828026

Address: Laddoo App Privacy Team, India

Response Time: We will respond to your inquiry within 30 days

15.2 Grievance Officer: For grievances related to data privacy, you may contact our Grievance Officer who will address your concerns within the timelines prescribed by applicable law.

16. LEGAL BASIS FOR PROCESSING (INDIA)

Under Indian data protection laws, we process your personal information based on the following legal grounds:

Consent: You have given explicit consent for specific processing purposes;
Contract Performance: Processing is necessary to provide services you requested;
Legal Obligation: Processing is required to comply with applicable laws (KYC, AML, taxation);
Legitimate Interests: Processing is necessary for our legitimate business interests (fraud prevention, service improvement);

17. COMPLIANCE WITH LAWS

This Privacy Policy complies with:

Information Technology Act, 2000 and Rules thereunder;
Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;
Digital Personal Data Protection Act, 2023 (when applicable);
Other applicable Indian laws and regulations;

18. ACKNOWLEDGMENT AND CONSENT

BY USING THE LADDOO APP, YOU ACKNOWLEDGE THAT:

You have read, understood, and agree to this Privacy Policy;
You consent to the collection, use, storage, and disclosure of your personal information as described herein;
You understand your rights and how to exercise them;
You acknowledge that this Privacy Policy may be updated from time to time;
You understand that your continued use after updates constitutes acceptance of changes;

This Privacy Policy is effective from January 2025. For any questions or concerns, please contact our Data Protection Officer at [email protected].