Privacy Policy


This Privacy Policy (“Policy”) which is effective from January 03, 2023, provides information about how we, Cowper Labs Private Limited, a company incorporated under the Companies Act, 2013 and having its registered office at 502 Indraprastha Ruhe, Whitefield Main Rd,Bangalore - 56006 (“Company”) collects, uses, stores, shares, transfers and discloses your information/data (used interchangeably hereafter) when you use the mobile application called “Wizely” that the Company operates, available for 6 download on Google Play Store and Apple App Store (the “App”).

The App consists of a proprietary mobile application developed by Wizely, Inc, a company incorporated under the laws of Delaware, having its office at 7302 Royal Oaks Ct., Pleasanton, CA 94566.

The App is aimed at bringing “Neo Banking Experience” for India’s 150M+ young and emerging consumers. Neo banking means a platform that delivers an intelligent banking experience in partnership with an ecosystem of traditional banking partners and non-traditional financial service providers on one platform that is simple, engaging and contextual to the customer's financial life.

The App provides a user with a neo-banking platform (“Platform”). The Platform enables registered users in availing banking and other financial products and services made available by different banking and other financial services providers who partner with us (“Platform Services”). The Platform facilitates opening savings bank accounts with Banks, making investments in gold, availing loan and overdraft facilities provided by the Partners and also facilitates making mutual fund investments and other financial goals through our various banking and financial services partners (“Partners”). Please refer to the Terms of Use for further information on the Platform Services and Partners.

Your privacy is important to us and we appreciate your trust in us. In this Policy, references to “you”, “your” or “user” shall mean the end user who accesses Wizely and avails its Services. References to “we”, “us” and “our” shall mean the Company. This policy contains the practices and procedures we follow in relation to the collection, processing and use of your information that you provide to us while using Wizely, in accordance with the provisions of the Information Technology Act, 2000 and the rules notified thereunder including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information), Rules 2011 (“SPDI Rules)

PLEASE READ THIS ENTIRE POLICY CAREFULLY. BY REGISTERING OR ACCESSING OR USING OUR PLATFORM IN ANY WAY, YOU AGREE THAT YOUR INFORMATION MAY BE COLLECTED, USED, STORED, SHARED, TRANSFERRED AND DISCLOSED AS DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE TO ALL THE TERMS OF THIS POLICY, WE RECOMMEND THAT YOU DO NOT USE THE PLATFORM.

BY USING THE SERVICES OR BY OTHERWISE PROVIDING US WITH YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE, SHARING AND/OR DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR PROVIDE US WITH ANY OF YOUR INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE OR AN ENTITY, YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

WIZELY DOES NOT HOST AND YOU SHALL NOT HOST, DISPLAY, UPLOAD, MODIFY, PUBLISH, TRANSMIT, STORE, UPDATE AND SHARE ANY INFORMATION THAT BELONGS TO ANOTHER PERSON AND TO WHICH YOU DO NOT HAVE ANY RIGHT; IS DEFAMATORY, OBSCENE, PORNOGRAPHIC, PAEDOPHILIC, INVASIVE OF ANOTHER‘S PRIVACY, INCLUDING BODILY PRIVACY, INSULTING OR HARASSING ON THE BASIS OF GENDER, LIBELLOUS, RACIALLY OR ETHNICALLY OBJECTIONABLE, RELATING OR ENCOURAGING MONEY LAUNDERING OR GAMBLING, OR OTHERWISE INCONSISTENT WITH OR CONTRARY TO THE LAWS IN FORCE.

WIZELY RESPECTS THE FUNDAMENTAL RIGHTS OF THE USERS IN ACCORDANCE WITH THE APPLICABLE LAW.

INFORMATION THAT WE COLLECT:

The information that we collect from you includes:

  • Your personal information such as your name, date of birth, postal address, e-mail address, mobile number etc. which are required to be provided by you at the time of registering on the Platform;
  • Fingerprint and PIN: You will be required to sign in to the Wizely App using a PIN, which you will provide for while signing-up. Additionally, you have an option to sign-in to the Wizely App with your the fingerprint functionality available on your mobile phone
  • Any other information which would help determine your eligibility to avail the services offered by us;
  • Your profile information such as your user name and password and details about your activity on the Wizely App
  • Information such as residential addresses which is required by our Partners to provide Services to you;
  • Any other information that we are required to collect as per specific mandate from any partner bank (“Partner Bank”) or other Financial Services Company as per applicable laws such as any information required to comply with the RBI/ SEBI mandated KYC norms (“KYC Information”);
  • In addition to the above, for mobile app: any other information that we are required to collect in order to provide smooth mobile experience, including but not limited to SMS access for the “Financial Snapshot” feature ,auto- OTP verification, camera/gallery/contacts access, for various functionalities within the app.
  • Transaction Information: We may access banking and financial transaction details related to your use within the ecosystem of the Platform which includes bank account details, one-time passwords, PIN transaction passwords, the date and time of such transactions etc. to (i) provide you with customized content on the Platform; (ii) monitor the Platform usage; and (iii) improve the content and services provided on and through the Platform..
  • Activity Information: We collect information about all your activities on the Platform to enable us to Service you better.
  • Device Information: When you visit or leave the Platform (including our plugins or cookies or similar technology on the sites of others), Wizely receives the URL of both the site you came from and the one you go to next. Wizely also gets information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. Wizely will ask you to opt-in before we use GPS or other tools to identify your precise location.
  • Internet: Wizely will access the internet or wifi network or any changes in the internet or wifi network of your mobile device for running the Platform. The Platform can only be accessed on your web browser if there is an internet connection.
  • Log Information: When you interact with the Platform, Wizely collects server logs, which may include information like device IP address, access dates and times, and other system activity, type of browser, and the third-party site or service you were using before interacting with the Platform to understand your usage of the Platform.

PURPOSE AND LIMITATION

Wizely uses the Personal Information and other data that is collected for the following general purposes:

  • To deliver the Services made available through the Platform;
  • To curate specific Services for you;
  • To respond to the request that you sent us such as your request for information, or your request to subscribe to a Service provided on the Platform;
  • To administer, protect and improve the Platform;
  • To better understand the preferences of users of the Platform;
  • To identify server problems;
  • To compile aggregated statistics about usage of the Platform;
  • To help personalize your experience of the Platform;
  • To improve services offered to you;
  • To help Wizely in its internal business functioning;
  • To the extent permitted by applicable law, Wizely may combine various types of data that is collected;
  • To share information in the manner specified in this policy; and
  • Any other use Wizely may describe at the point when it collects data.

STORAGE AND RETENTION OF YOUR INFORMATION

We retain your data for the duration of your use of the Platform for the aforementioned purposes. We archive your data and store it to comply with any data requests by Government authorities. We shall store your data: (i) no longer than necessary for the purposes for which the personal information is received and processed; or (ii) as maybe required to be stored under applicable laws.

All KYC Information is only collected on behalf of our Partners as mandated by applicable laws, for facilitating authentication by Partners. We do not process or store any KYC Information of the User.

Your data is collected by and retained by Cowper Labs Private Limited, a company incorporated under the Companies Act, 2013 and having its registered office at 502 Indraprastha Ruhe, Whitefield Main Rd, Bangalore – 56006.

SECURITY FOR YOUR INFORMATION

Wizely follows generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including utilization of encryption where appropriate.

  • We use HTTPS for secure transmission of data from end-user systems to our cloud server.
  • All passwords are stored in a database in encrypted format using AES 128 bit encryption.

DATA SECURITY BREACH

Transmissions over the Internet are never 100% secure or error-free. However, Wizely takes reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Wizely has implemented strict security controls, intrusion detection software and processes to alert us in the case of a potential or actual intrusion of our information systems. Wizely has a data breach notification system in place and an established incident response team that will react immediately and execute a remediation plan in response to any unauthorized access to Wizely’s or the Platform’s information systems or databases. If any data security breach occurs and it may impact your personal information, you will be notified as soon as possible once the breach has been determined.

ACCESS

If personal information you have submitted through the Platform is no longer accurate, current, or complete, you are allowed to update these changes using the Platform, but Wizely reserves the right to use information obtained previously to verify your identity or take other actions that it believes is appropriate.

COOKIES POLICY

Cookies are small pieces of identifying information, stored by your browser on your PC and mobile, to enable information about your session on the website/mobile application to be maintained. The cookie may contain actual information (e.g. the date of your last visit), or just a unique reference ID that allows the website to look up information about your use.

If the Platform sets cookies routinely, these can also be used to track your successive page views, and therefore your behavior on the Platform, whether or not you are logged in. Unless you login or complete an enquiry form, such use of cookies will not enable the Platform to identify you (because cookies can only give access to information that the Platform already has). The Platform will not attempt to identify you unless you log in.

Cookies set by one site cannot be read by another. However, one web page may be made up of components (such as news stories, images or advertising), some of which are delivered from third parties. Each of those third-party sites will be able to set and read its own cookies on any page where its content appears. Wizely allows other companies such as web/mobile analytics partners to set or access their cookies or web beacons or similar technologies on the Platform. For example, Wizely may use third party mobile analytics partners to analyze big-data on its behalf. These third-party analytics partners employ cookies, web beacons and other similar technologies to measure and analyze the big-data. To do so, these partners may use information about your use of the Platform which information will be anonymized such that it cannot reasonably be used to identify you. This data can also be used for online marketing purposes by Wizely.

Cookies Usage

Wizely uses cookies, device fingerprinting, open device identifier number or similar technologies to collect the information described above. Wizely may also use the above-mentioned technologies to (i) provide you with customized content on the Platform; (ii) monitor the Platform usage; and (iii) conduct research to improve the content and services provided on the Platform.

If you block cookies from the Platform, you will not be able to log in, and a range of other functions, such as the tracking of new messages in the discussion forums, will fail. However, you will be able to browse most of the information on the Platform. The Platform uses some third-party services, and you may need to consult their policies separately.

Using your browser to block cookies, and further information

Most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, your overall user experience may get affected such as not having customized access to the Platform. It may also stop you from saving customized settings like login information. If you have questions about our use of cookies, please contact: contactus@wizely.in

  • We share your personal information with third parties including Partners who perform services on our behalf. We share information with vendors who help us manage our online registration process or payment processors or transactional message processors.
  • We share information with third parties and or business partners who partner with us on the Platform.Each of the Partners have their own privacy policies. The business partners will include banking and other financial service providers and other partners on boarded by us onto the Platform.
  • We will share information with our other corporate entities and affiliates. These entities and affiliates may market themselves to you as a result of such sharing unless you explicitly opt-out.
  • We may share information if required to do so by law. We will share information to respond to a court order or subpoena. We may also share information if a government agency or investigatory body so requests. Or, we may also share information when we are investigating potential fraud.
  • We may share information with any successor to all or part of our business or assets. For example, if part of our business is sold or if substantial assets of ours are sold, we will transfer your data to such successor / buyer as part of that transaction.
  • We may share your information for reasons not described in this policy. We will inform you before we do this. The collection, storage and processing of data by the above third parties either pursuant to us sharing it with them or where you submit the data directly, are subject to their own data protection policies and security practices.
  • At all times, we shall ensure that we share your information with third parties who ensure the same level of data security measures as us. We are in no way privy to the data protection practices of these parties and is not responsible for their adherence to data protection norms.
  • We conduct from time to time contests for our users. We may use third party service providers to collect and collate data for such contests. We may share your information with such service providers during contests.

LIST OF THIRD-PARTY SERVICE PROVIDERS

Wizely uses the following third-party service providers which will store and retain your data for the provision of services as detailed under the Terms of Use, as applicable

Name of Third-Party Service Provider Contact Information
Amazon Web Services https://aws.amazon.com/
Razorpay Software Private Limited 1st Floor, SJR Cyber, 22 Laskar Hosur Road, Adugodi, Bengaluru, 560030, Karnataka, India
grievances@razorpay.com
MoEngage https://www.moengage.com/, privacy@moengage.com
ICICI Bank Limited ICICI Bank Tower, Near Chakli Circle, Old Padra Road,Vadodara, Gujarat - 391440
ICICI Prudential Asset Management Company Limited 12th Floor, Narain Manzil, 23, Barakhamba Road,New Delhi 110 001
Digital Gold India Private Limited 2nd and 3rd Floor, CoWrks, Birla Centurion, Pandurang Budhkar Marg, Worli, Mumbai – 400030

CHILDREN’S PRIVACY

The Platform is intended for use by adults only. Wizely does not intentionally or knowingly collect personally identifiable information from minors (under the age of 18) and requests that minors (under the age of 18) do not submit any personal information on the Platform.

AMENDMENTS

Wizely reserves the right to change, modify, add or remove portions of this Policy at any time, but will alert you that changes have been made by indicating on the Policy the date it was last updated. When you use the Platform, you are accepting the current version of this Policy as posted on the Platform at that time. It is recommended that users revisit this Policy on occasion to learn of any changes.

GRIEVANCE OFFICER

If you have any questions, or concerns about this Privacy Policy or any complaints or grievances about the manner in which Wizely handles your personal information or the use of your personal information (in doing so acknowledging that Wizely may be unable to provide you all or some of the services), please feel free to contact the Grievance Officer any time at:

Name: Mr. Dennis Kumar
Contact Details: contactus@wizely.in

A. Acknowledgement

  1. If you visit any third party websites or links that may be available on the website, please note that the use and collection of your data will be governed by such third party’s privacy policy, and we shall not be liable in any manner whatsoever for use and processing of such data by third parties.

  2. By agreeing to this policy, you also agree to not host, store, transmit, display, upload, modify, share or publish, on our website or any such platform (e-mail groups etc) which you are a part of, by virtue of accessing or using the website or by virtue of using our products or by availing our services, any information that
    1. belongs to another person and to which the user does not have any right;
    2. is defamatory, obscene, pornographic, paedophilic, invasive of another's privacy, including bodily privacy, insulting or harassing on the basis of gender, libellous, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or otherwise inconsistent with or contrary to the laws in force;
    3. is harmful to child;
    4. infringes any patent, trademark, copyright or other proprietary rights;
    5. violates any law for the time being in force;
    6. impersonates another person;
    7. threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign States, or public order, or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting other nation;
    8. contains software virus or any other computer code, file or program designed to interrupt, destroy or limit the functionality of any computer resource;
    9. is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity or agency for financial gain or to cause any injury to any person.

Note: You acknowledge and agree that merely un-installing the Platform from your mobile device will not result in the deletion of your information from the Platform and you will have to send an email to contactus@wizely.in if you wish to have all your information deleted from the Platform databases and servers.

THE USE OF THE PLATFORM OR ANY PART OF THE SERVICES ON THE PLATFORM, EITHER IN WHOLE OR IN PART, SIGNIFIES YOUR AGREEMENT TO THIS PRIVACY POLICY.