Privacy Policy

Definitions In this Privacy Policy, unless the context specifies otherwise:
  1. Earn Activity(ies)” means any transaction or action that results in the accrual of m.Paani Points for an m.Paani Member.
  2. Member(s)” means an m.Paani customer, who opts to enroll in, and participate in, the Program.
  3. Membership” or “Membership Account” means the m.Paani account where the m.Paani Member's Points will be accumulated.
  4. “Missed call service” is a facility available to the applicant once he registers himself as a member with the service provider.
  5. m.Paani helpline” shall be the communication channel provided by m.Paani to its Members.
  6. MPaani Solutions Private Limited” hereinafter referred to as “m.Paani” is a private company incorporated under the Indian Companies Act, 1956.
  7. Partner(s)” are any present or future individuals and / or entities with which Members can accumulate Points for specified actions or transactions.
  8. Phones(s)” shall mean phone(s) owned/ in control of the customer which supports voice and data exchange offered by a Telecom Service Provider and having distinctive phone number.
  9. Point(s)” are the currency of the Program.  Members earn Points from Partners associated with the program and exchange these Points for Rewards.
  10. “Program” refers to the m.Paani rewards program, defined, managed and operated by m.Paani, through which m.Paani Members accumulate Points for Earn Activities at Partner companies specified by m.Paani from time to time.  These Points can then be redeemed for current Rewards offered by Suppliers.
  11. "Redemption" means any activity, which results in exchange of Points by a Member for valid m.Paani Rewards included in the current Rewards Catalog.
  12. Reward(s)” refers to any goods or activity for which m.Paani Points are exchangeable.
  13. Rewards Catalog” refers to a list of all current, valid m.Paani Rewards.  This Rewards Catalog will be produced by m.Paani and made available to Members.
  14. “SMS” means short messaging service these are the alerts sent in the form of response to the customer over his mobile phone from time to time.
  15. Supplier“ shall mean a third party responsible for services, or the manufacturing of goods offered, as entire or components of Rewards to Members.
  16. Telephone Service Provider(s)” shall mean any person/organization permitted by the Government of India or any competent authority to provide telephone services in India that support voice and data traffic.
  17. “Terms and Conditions” refers to the separate Terms and Conditions made available by m.Paani to Members at www.mpaani.com/terms
  18. Working Days” means the days in the period from Monday to Friday excluding public holidays.
Privacy Policy Background
  1. m.Paani represents a network of Partners and Suppliers that are interested in providing relevant offers and services to Members, and the Members who are interested in receiving these offers and services. To ensure that the offers and services are relevant we may solicit information from the Members from time to time. This is solely for the purpose of making the Program more meaningful. We are committed to protecting the privacy of our Members and their transactions.
Protection Of Information This section explains how we protect and use Members’ information in a safe, secure and responsible manner
  1. m.Paani safeguards Members’ data by:
    1. Setting policies and procedures for carefully handling Members’ information
    2. Limiting access to sensitive information
    3. Protecting against unauthorized access to Member data
    4. Authentication and virus detection technology
    5. Requesting Partners, Suppliers and other companies m.Paani interacts with to comply with privacy laws
Collection Of Information
  1. m.Paani collects and uses various types of information to manage Members’ participation in the Program. Member information is collected under the following categories:
    1. Personal Information:
      1. Personal Information refers to any information that can be used to identify Members as an individual in any way. Enrolment in the Program is contingent upon Members agreeing to the Terms and Conditions provided separately and providing enrolment information such as name, mobile telephone details, address details, language preferences, employment details, education details, related m.Paani Members and any information about the registered SIM owner if applicable. Members may additionally need to provide m.Paani with other Personal Information in order to fully benefit from participation in the Program. This may include demographic and other details.
      2. m.Paani may use Members’ mobile telephone number or a unique membership number to identify individuals as a Member of the Program and to fulfill the rights and obligations of m.Paani as per the Terms and Conditions.
    2. Additional Information:
      1. In addition to any personal information provided as a part of the enrolment process described in Clause (1)(1)(1) in this section, m.Paani may from time to time request that the Member provide additional information in order to provide the Member with offers and services that pertain to the Member’s preferences and profile.
      2. This information is not mandatory, and may be provided at the Member’s sole discretion. However, such information may be required by m.Paani in order to provide notice of and access to relevant promotions and offers.
    3. Transaction Information:
      1. m.Paani will collect information on transactions linked to the Program and the Member’s m.Paani Membership that are required for processing of Points, including credits and debits, to Members’ m.Paani Membership Accounts. By definition this shall include all transactions with m.Paani, Partners, Suppliers, all promotional campaigns through telephone, SMS, or any other communication channel, at any other participating affiliates, subsidiaries, program partners, surveys and more.
  2. All of the above is collected by m.Paani in order to:
    1. Service Members and m.Paani Membership Accounts including providing Members with information such as m.Paani Membership Account Points balances.
    2. Ensure that communicated promotions and offers are relevant to Members.
    3. Track Points transactions, of help in case of any dispute situations; processing m.Paani Rewards orders alongside Suppliers; managing requests, enquiries or complaints and other customer care related activities; and all other general administrative and business purposes; marketing m.Paani’s, Partners’ and Suppliers’ products and services; carrying out any activity in connection with a legal, governmental or regulatory requirement or in connection with legal proceedings, crime or fraud prevention, detection or prosecution. This will involve providing information to third parties including, but not limited to, Partners and Suppliers.
    4. Effectively administer and fulfill m.Paani’s obligations under the Terms and Conditions.
    5. Seek feedback or contact Members with offered services.
    6. Register details and provide Members with notification of and access to Rewards or other Program benefits.
    7. Provide insight to Partners and Suppliers, current and prospective, about the impact or potential impact of the m.Paani Program on their business operations. This may include aggregate-level as well as anonymized member-specific information where the latter is required.
Provision Of Information To Third Parties
  1. In certain instances m.Paani may be required to provide all collected information to third parties outside of m.Paani, their Partners and Suppliers, as permitted by law, such as:
    1. Responding to judicial process.
    2. To consumer reporting agencies.
    3. In connection with a proposed or actual sale, merger, or transfer of all or portion of m.Paani.
    4. To protect against fraud, money laundering or other risks.
    5. To third party services for the purpose of implementing marketing research and services and customer support services.
Information Storage
  1. All information shall be stored in m.Paani’s databases which are located remotely and not in any specific physical location. m.Paani reserves the right to hold all information indefinitely.
  2. m.Paani may occasionally share information with trusted third parties including data processors to organise, process, clean & analyse our data to help m.Paani better understand Member trends and segments. m.Paani shall use this information solely with the purpose of enhancing the value of the Program for Members and to better tailor m.Paani’s offers to Members’ specific interests. All such third parties shall be under non-disclosure agreements and strictly bound to maintain the confidentiality of the information shared and will not share Members’ personal information any further or for purposes beyond m.Paani’s specific authorization.
  3. We intend to share data with our sponsors, advertisers, Partners and Suppliers in aggregate form, but we will ensure that the program is designed to make sure Members are not identified personally to any third party unless required to provide essential Program functions as determined by m.Paani or as specified in the "Provision Of Information To Third Parties" section above. Such essential functions include, but are not limited to, crediting m.Paani  Membership Accounts with Points where the transaction requires reference to a specific individual and facilitating Redemption, or Reward activities that are highly personal such as classes or require physical home delivery.
  4. Occasionally, Members may want to avail of services or offers that, by the very terms, will require us to forward information to the advertiser, Partner or other third party so that they can provide the service to Members. In such instance Members will be governed by the privacy policies of such advertiser or partner with whom Members share information. It is the responsibility of Members to ensure they understand the privacy policies of such advertisers, Partners or other third parties prior to disclosing any information. By consenting to this privacy policy, the Member agrees that m.Paani will not be held liable for any misuse of Member information by a third party.
  5. Redemption requiring mailing of vouchers, gift items or rewards to the Member’s mailing address will require that m.Paani part with Members’ personal information to the extent required, with the Supplier, for delivery. As before, strict compliance with a non-disclosure agreement will be sought. This Supplier will not share the personally identifiable information any further or for purposes beyond m.Paani’s specific authorization.
  6. m.Paani will provide Members with the choice to participate in offers from Partners. Beyond personal information already provided to Partners by m.Paani as per Clause (3) in this section, it is a Member’s decision whether or not to share their personally identifiable information with Partners as part of such offers. m.Paani recommends that Members carefully read Partner’s privacy policies where applicable  before divulging personal information to these Partners, as m.Paani will not be held liable for the information practices of third parties. Members may receive promotional offers and campaign details by telephone, SMS, or any other communication channel.
  7. Selectively, Members may also receive Program offers via other communication channels. Such contacts may result in physical delivery of Rewards to the Member. m.Paani may also contact Members via telephone, SMS, physical mailings or any other communication channel for administrative purposes, such as program change notifications or if m.Paani updates the Terms and Conditions or Privacy Policy. Members cannot unsubscribe from these administrative messages while enrolled in the program. m.Paani may contact Members in response to inquiries submitted by these Members. m.Paani may also contact Members with regard to a particular problem that may have occurred with a Member’s account or with an offer in which a Member may have participated. m.Paani may use this information to learn more about Members’ participation in the program and make it more relevant to these Members’ interests.
Adherence To Prevailing Law
  1. m.Paani is committed to follow the laws laid out with regards to telecalling and telemarketing and follows the guidelines set by any regulatory authority including TRAI in cases of DND policy or any such similar law or regulation which may be in force.
Aggregate Data
  1. m.Paani does not provide Members’ personally identifiable data to advertisers and other third parties except as specified in Clause (3) of the "Information Storage" section above.
  2. Because m.Paani contacts Members on advertisers’ and other third parties’ behalf, advertisers and other third parties do not have access to Members’ personally identifiable information unless Members make the choice to share it with advertisers or other third parties. m.Paani may share non-personally identifiable information collected via the program in aggregate (or grouped), anonymous form with advertisers or other third parties so that they may better evaluate what products and services are most appealing to different segments of our member base, but m.Paani does not disclose Members’ personally identifiable information to these third parties unless Members give express consent.
Anti-Spam Policy
  1. As telephony and SMS are integral parts of the Program, Members’ sharing of telephone contact details with m.Paani allows m.Paani to share Program information, offers and promotions via telephone or SMS with Members.
Automatically Collected Information
  1. When Members interact with the Program or transact with Partners, information is collected related to these interactions and transactions and is attributed to a Member’s m.Paani Membership Account. The telephone from which these interactions and transactions occur acts in certain instances as a Member’s unique identifier, which allows m.Paani to recognize Members and authorize Members’ transactions. It also allows m.Paani to keep track of Members’ activity for crediting points to a Member’s m.Paani Membership Account. This information may be used to target Members with offers and advertisements.
Security Of The Information
  1. Member privacy and the protection of Member data is of the utmost concern to m.Paani. m.Paani maintains physical, electronic and procedural safeguards to protect Member information. Specific m.Paani, Partner and Supplier employees only are authorized to access customer information on a restricted basis for business purposes only, as determined by m.Paani, Partners and Suppliers. m.Paani, Partner and Supplier employees may be bound by a code of ethics or a legal agreement that requires confidential treatment of Member information and may be subject to disciplinary and even legal action if they fail to follow this code.
  2. However, m.Paani shall not be held liable for any breaches of security or any misuse of information by m.Paani, Partners or Suppliers.
Ensuring Member Information Accuracy
  1. It is m.Paani’s objective, and in the interest of Members, for m.Paani to have accurate, current and complete information concerning Members and Members’ m.Paani Membership Accounts. m.Paani has strict procedures that our employees abide by to meet this objective.  If a Member believes that m.Paani has incorrect information about that Member or their accounts, we ask that the Member contact m.Paani to correct this. m.Paani will correct any erroneous information as soon as possible.
Complaints And Queries
  1. In the event of any complaints or queries regarding the Program, Members are asked to contact m.Paani by contacting the help line through communication channels publicized in program materials.