As a part of our ongoing efforts to ensure the compliance to modern banking approach, customer trust/ satisfaction, security-oriented service and banking services, we, RBL Bank Limited (“RBL Bank”), have adopted Privacy Commitment (“Statement”) aimed at protecting the personal information entrusted and disclosed by the customer while using RBL Bank’s Digital Platforms. Digital Platform(s) shall mean our mobile applications, website, online services and other digital platforms. This document governs the way in which we collect, use, disclose, store, secure and dispose personal information (which shall mean and include personal information as well as sensitive personal data). In the course of using RBL Bank’s Digital Platforms, RBL Bank and its affiliates may become privy to the personal information of its customers, including information that is of a confidential nature. When you use our Digital Platforms, you are expressly agreeing to and consenting to the terms of this Statement and by any use of our Digital Platforms you will deemed to have given your consent for the processing of your Personal Data as set out in this Statement

Type of user data collected and their purpose:

All the below permissions are used when RBL Bank Digital Platforms is in usage (foreground).

1. SMS - Collect this permission to send and view messages to verify your registered mobile number and SIM card for meeting the mandatorily required provision by Reserve Bank of India (RBI) rules for Unified Payment Interface (UPI) authentication and to auto fill OTPs you receive via SMS on your device. We collect and monitor only financial transactional SMS initiated by RBL for description of the transactions and the corresponding amounts. Other SMS data is not accessed by us.
    
2. Location - Collect and monitor information about the location of your device, to offer you customized products and services e.g. , to check the locker availability near you, to check availability of nearby RBL Bank branches in your geography, etc.
    
3. Phone - Collect and monitor specific information about your device including your hardware model operating system and version, unique device identifiers like IMEI and serial number, user profile information, wi-fi information, and mobile network information to uniquely identify the devices and ensure that unauthorized devices are not able to act on your behalf to prevent frauds.
    
4. Contacts - Collect your contacts information to automatically detect references information from your contact list during runtime for making payment to your contacts, use of recharge or bill payment facility.
    
5. Storage - Use storage access for statements, downloadable PDFs and QR Codes. Use the above permitted information for analysis of your business interest and to improve our products and services to meet your needs and to recommend suitable products and services to you. The above information is securely stored on your device and may be accessed by the application based on its requirement.
    
6. Other information - Other Information that cannot be reasonably used to identify a particular individual which may include information about your device, information collected through tracking technologies, demographic information, employer’s name and address (if self-employed, type of account, and nature and volume of anticipated business dealings, with the conventional bank licensee, income proof, bank statements, income tax returns, salary slip, contract of employment, passbook, debit card/credit card details, expenditure, assets and liabilities, source of wealth, signature, Social relationships detail such as your father’s name, spouse’s name and mother’s name, Records of correspondence and other communications between us, including email, telephone conversations, live chat, instant messages and social media communications containing information concerning your grievances, complaints and dispute & as well as your other bank account details that you provide to us.
    
7. Biometric information - Information such as your fingerprint, etc. that you choose to provide to us for authentication purposes and for the purpose of usage of the Apps. Please note we will not collect your biometric information without your explicit consent.
    

Purpose of collection of personal information - You agree that we may use your personal information for the purpose of, among other things, statistical analysis and for creation of data ("Statistical Information"), customer verification, provision of products and services, for personalization of products or services, marketing or promotion of our financial services or related products or that of our associates and affiliates; credit scoring, enforcement of your obligations, any other purpose that will help us in providing you with optimal and high quality services. In addition to the information that we collect from you to better serve your interests, you are free to volunteer any other information that you feel that we need to know, however the security and confidentiality as per this Document is pertaining only to the information that we directly ask from you.

This Document will also be applicable to a non-customer who has provided information to us, by any means, with the intention of establishing a relationship, of whatsoever nature, with us. By divulging any information to us you agree to the terms this document.

Detailed information on the processing of Personal Data

Registration and Authentication - When you register for RBL Bank Digital Platforms you are accessing a RBL Account that is associated with your relationship with RBL Bank. Depending on including but not limited to RBL Bank Digital Platforms services that you use, you may be asked to provide the following information: CIF, PAN, Passport, Debit Card Number, Internet Banking Password and in some cases, we may also ask you to send us additional information or to answer additional questions to help verify your information.

In addition, we also use Unified Payment Services within our App. As required by RBI, we will be asking for additional SIM based authentication by sending a secure SMS verification from the phone. This allows us to verify that you are the authorized users of the SIM card in your phone.

Analytics -The services contained in this section enable RBL Bank and its appointed third parties to monitor and analyze traffic within the RBL Bank Digital Platforms as per business requirement, can be used to keep track of User behavior and send push notifications.

Security - We have taken reasonable measures to protect security and confidentiality of your personal information and its transmission through internet. You are required to follow the applicable terms and conditions while using RBL Bank Digital Platforms including the instructions stated therein in respect of security and confidentiality of your log-in and password.

We will give access to your personal information to only authorised employees. Employees who violate this document shall be subject to disciplinary process as per internal policies of the Bank.

Review and amendment of personal information - You are free to (i) review and amend the personal information provided to us earlier, (ii) withhold your consent for the collection of any personal information or (iii) withdraw any prior consent that you may have provided for collection of personal information, at any time, by denying the permission from settings. However, please note that once consent is withdrawn, we may not be able to provide you with services which depend on such consents.

Disclosure – We shall not be held liable for disclosure of your personal information or Statistical Information in accordance with this Privacy Document or in terms of any other agreements with you.

We may disclose the Statistical Information to any person, without any limitation and you hereby give your irrevocable consent for the same.

We may disclose the personal information, to the following third parties, for the purpose mentioned under this Document and you hereby give your irrevocable consent for the same:-

1. Any agent or third party service provider who provides administrative, telecommunications, computer, payment or securities clearing or other services to us in connection with the operation of business;
2. Any other person under a duty of confidentiality to us including our Group company, which has undertaken to keep such information confidential;
3. The drawee bank providing a copy of a paid cheque (which may contain information about the payee) to the drawer;
4. Credit reference agencies, and, in the event of default, to debt collection agencies;
5. Any person to whom we are under an obligation to make disclosure under the requirements of any law binding on us; and
6. Any of our actual or proposed assignee or participant or sub-participant or transferee of our rights in respect of the customer
         

We may disclose the personal information for the following reasons as well:

1. To comply with legal requirements, legal process, legal or regulatory directive/ instruction. or
2. To enforce the Terms and Conditions of the products or services. or
3. For fraud prevention purposes. or
4. To capture the location by using its internal services or any third party services and to preserve the records in its own server or server of the third party. Customer’s location maybe accessed to improve features of the mobile app such as displaying nearby offers, branches or sending location specific deals via notification or for any other purpose which, directly or indirectly, improves the features of the mobile app. Customers location is retained solely for the purpose of enhancing Customer experience. RBL Bank may use and share the information provided by the Customers with its affiliates and selected and credible third parties for providing services and any service-related activities
5. Act to protect the interests of RBL Bank, its Affiliates, or its members, constituents or of other persons.

The Customer would be required to cooperate with RBL Bank in order to ensure the security of the information, and it is recommended that the Customers necessarily choose their passwords carefully such that no unauthorised access is made by a third party. The Customers should undertake not to disclose their password to anyone or keep any written or other record of the password such that a third party could access it.

The Customers shall not disclose to any other person, in any manner whatsoever, any information relating to RBL Bank or its Affiliates of a confidential nature obtained in the course of availing the services through the RBL Bank Digital Platforms . Failure to comply with this obligation shall be deemed a serious breach of the terms herein and shall entitle RBL Bank or its Affiliates to terminate the services, without prejudice to any damages, to which the customer may be entitled otherwise.

"Cookies" are bits of electronic information that can transfer to your hard drive, mobile device, or other device to keep records of your use or visit to RBL Bank Digital Platforms. We may use cookies to improve your experiences when visiting or using RBL Bank Digital Platforms.

We may use cookies to anonymously track interests, and collect aggregate information when you use or visit our App. We do not use cookies to store or transmit any Personal Data.

Log files" are files that anonymously log actions that take place on the app. We may use log files to gather statistics about your browsing habits and to assess overall digital activity, including how many "hits" a particular page is getting. Log files enable us to track interest in specific promotions, troubleshoot technical concerns, and provide content that may be of interest. We also use the log file entries for our internal marketing and demographic studies, so we can improve the app we provide to customers and visitors. Log files are used internally only, are anonymous, and are not associated with any particular user, device, computer, or browser.

SDK Policy
If you use the RBL Bank Digital Platforms, we may use third party SDK’s within the RBL Bank Digital Platforms as per business requirement, cookies and other similar tracking technologies.

How we use data collected via SDK’s

1. To operate and improve the app
   • Enable you to use app feature.
   • Communicate with you about the app, including by sending announcements, updates and security alerts which we may send through a push notification, and responding to your questions and feedback.
   • Perform statistical analysis about use of the app measure and analyze effectiveness of marketing campaigns.
      
2. To send you marketing and promotional communication
   • We may send you marketing communications as permitted by law.
   • We might do the following analysis with aggregated data (no PII is stored or used at any given point in time).
   • Customer Journey Analysis: Conversion funnels such as from Home Page to Product Page to Lead Form.
      

Traffic Analysis: Marketing channel categorized by visits, unique visitors, bounces etc.

RBL Bank may, from time to time, at its sole discretion modify/update this Statement. Any update to this Statement becomes effective as and when the modifications have been uploaded on RBL Bank Digital Platforms. Your use of RBL Bank Digital Platforms post any update to the Statement shall be construed as deemed acceptance to the updated Statement and will amount your consent to the use and sharing provisions identified in the Statement.