The Dhoni App is provided to you using Single.id technology by Enigmatic Smile Rewards Private Limited. This privacy notice tells you what to expect when Enigmatic Smile Rewards Private Limited (“we”/“us”/“our”) collect information about you or your actions when using the Dhoni App.
This Personal Data Policy (hereinafter referred to as the “Policy”) applies to your use of the loyalty program. The loyalty program gives you as a user the opportunity to obtain Rewards (hereinafter referred to as "vINR") from the participating companies. The loyalty program is hereinafter referred to as "Single.id" (Single.id). Single.id is operated by Enigmatic Smile Rewards Private Limited (hereinafter referred to as “SID”).
The personal data policy applies to all Single.id channels, regardless of whether you access Single.id via the website or the app (hereinafter referred to as the “Platforms”).
Your personal data is processed in accordance with the Policy and applicable legislation.
1. SID is responsible for the processing of your personal data.
SID’s addresses are:
Enigmatic Smile Private Rewards Limited: 12,13,14 F, Wework, 247 Park, LBS Marg,
Vikhroli-West, Mumbai -400079
Enigmatic Smile Limited (UK Parent company, company number: 08869163): Swift
House Ground Floor, 18 Hoffmanns Way, Chelmsford, Essex, England, CM1
1GU
to be able to invoice companies for your earned v INR. This processing
is necessary for the agreement with you as a user to be fulfilled.
With your consent, your e-mail address and mobile phone number are
also used for sending marketing material from Single.id.
2. Other general personal data
SID may collect other general personal data if you enter this in your user
profile on the Platforms. This could be for example, information about your
date of birth, your age, number of people in your household, your gender,
and your postcode. Entering such information is always optional for you.
However, we can make an estimate of your gender and your postcode based
on your entered name and your geographical location, if you have given
consent to the collection thereof.
1. Purpose and basis
This personal data is processed in order to carry out targeted
marketing and offer you relevant opportunities to use Single.id.
3. Payment card information
SID processes information about your payment card number, expiry date and
name of the cardholder. SID only collects this information when you add your
card details. In the event that you wish to make a payment for an additional
service, you must also enter the card's CVV/CVC. You may be asked to
provide your CVV/CVC when registering your card. SID does not store your
CVV/CVC, but uses this to authorize a specific payment or to authorize your
card.
Your payment card information is only processed in an IT environment that is
certified according to the PCI (Payment Card Industry) rules.
1. Purpose and basis
SID needs your card details in order to register which purchases you
make where you are entitled to receive a vINR reward. The processing
is necessary to be able to fulfil the agreement with you.
4. Payment information
SID processes information about the purchases you make with a payment
card registered to Single.id. SID processes information about the time of
purchase and the amount you purchased for. With your express consent, SID
also processes information about where you made the payment. If you do
not wish to notify SID of your consent, SID cannot provide the service to
you. SID does not process information about what you have purchased,
unless it is necessary for the purpose of calculating a Reward.
1. Purpose
Your payment information is processed so that SID can calculate how
much vINR you are entitled to. This is necessary in order to fulfil the
agreement with you.
2.
With your consent, SID also uses information about your purchases
for targeted marketing and to be able to offer you relevant
opportunities to use Single.id.
5. Customer number
SID processes your customer number in connection with payment of your
vINR Rewards. Some payment methods require you to provide your customer
number with the company to which the payment is to be made, e.g. if you
want to offset a payment with your vINR. SID only collects this information
when if you provide it in order to collect rewards.
1. Purpose and basis
The purpose of the processing is that SID can allow you to use your
vINR in the manner that you have requested. For example, you may
have asked that your vINR be used for offsetting a bill or similar.
6. Contact List
you can invite a friend or send rewards to a friend, to do this, you will need to
grant SID access in the app to your contact list. When you authorise access to
your contact list, the personal data in your contact list is accessed (but not
stored) to check if anyone in your contact list already has an account, if they
do not and you have indicated you would like to invite them, we will notify
you of this and explain how you can invite them.
1. Purpose and basis
The purpose of the processing this information is to make it easy for
you to receive and send rewards to/from other users within the app.
In addition, it allows you to send an invite link to a person who is not
already onboard. Please ensure you have informed them and they are
happy for you to do so, before inviting them. We process this personal
data under our legitimate interest and to perform our contract with
you. We have done a balancing test to ensure that we are processing
the personal data fairly and proportionately.
7. Geographical location
With your consent, we process information about your geographical location.
1. Purpose and basis
The purpose of the processing is that Single.id can target its marketing
and show you companies (shops, restaurants, webshops, etc.) that
offer vINR near you. We may also use your geographic location to
make an estimate of your current residence post code.
8. Targeted marketing / profiling
1. SID can carry out profiling in order to provide you with relevant offers
and adapt our marketing to ensure that you receive the offers that
are most likely to correspond to your personal interests and
needs. The profiling does not mean that you are cut off from certain
offers, products or services, but only aims to target the marketing as
best as possible based on your personal interests. SID only sends
direct marketing to e-mail if you have given consent to this.
4. Disclosure of data
1. The personal data about you that SID processes will not be passed on to third
parties without your consent, unless SID has another legal basis for the
disclosure.
SID passes on information about the amount spent, the vINR added to your
balance and the time of the transaction to the companies connected to
Single.id in order to invoice for your vINR. This processing is necessary for SID
to fulfil its agreement with you.
When you shop with a store, SID passes on information about your age,
gender, postal code as well as the amount spent, the vINR paid to you and
the time of the transaction.
If you choose to "follow" a store on the Platforms, SID can pass on your first
name, age, gender and postal code, the amount spent, the vINR paid to you
and the time of the transaction to the store and will update your news feed
with targeted marketing.
SID may also pass on your personal data to comply with the law, in
connection with a legal process and to comply with requests from public
authorities.
2. SID receives transaction information based on your purchases from
registered companies with registered payment cards, so that SID can
calculate the vINR due to you on your registered payment cards from
payment providers. SID can exchange this information with SID's sub-
suppliers with the aim of being able to identify and calculate vINR for your
purchases at registered companies (shops, restaurants, webshops, etc.).
3. As a user, you consent to your payment card being registered for rewards
and to your card number being passed on to payment providers connected to
SID. You also consent to these companies processing information about
where, when and for what amount you have spent using your card in order to
calculate your vINR. Information about what you have purchased will not be
processed.
4. We use the information we receive about your vINR and collect from you to
be able to create targeted marketing for you. In this connection, we pass on
pseudonymised information to third parties for the purpose of optimizing our
marketing efforts.
5. Enigmatic Smile Rewards Private Limited also collaborates with a number of
sub-suppliers/data processors and group companies where personal data is
shared securely and only where necessary for operational purposes and to be
able to perform under the terms and conditions agreed with all end users.
This includes:
1. Enigmatic Smile Limited (company number: 08869163)
which calculates the vINR, stores card data and other collected
personal data and sends service messages to users.
6. SID has concluded data processing agreements with its data processors. The
agreements determine the obligations that the data processor must comply
with when it processes your personal data on our behalf. The data processor
can thus only legally process information about you to fulfil the stated
purposes.
5. Storage
1. Personal data is not stored longer than is necessary to fulfil the purpose for
which it was collected, unless the storage is necessary to meet national legal
requirements, including statutory storage periods in connection with
bookkeeping etc.
2. SID stores your personal data until you unsubscribe from the Single.id, after
which your personal data is either deleted or pseudonymised. If you revoke a
consent, the personal data previously processed under the consent will be
deleted or anonymised, unless we have another legal basis for continued
processing.
6. Rights
When SID processes your personal data, you as a registered user have a number of
rights. These personal data rights are listed below. If you wish to assert one or more
of your rights, you are welcome to contact SID at any time.
1. Right to access: You have the right to access which personal data SID has
registered about you.
2. Right to rectification: You have the right to have personal data that SID
processes about you corrected if the personal data is incorrect or misleading.
3. Right to deletion: In certain cases, you have the right to delete personal data
that SID processes about you.
4. Right to restriction: You have the right for SID to temporarily limit its
processing of your personal data to storage only in certain cases.
5. Right to data portability: In certain cases, you have the right to have personal
data that you have provided to SID handed over in a structured, generally
usable and machine-readable format.
6. Right to object: You have the right at any time, based on your particular
situation or special reasons, to object to SID's processing of your personal
data. You can also object to the processing of your information for direct
marketing, including profiling. If your objection concerns the use of your
personal data for direct marketing purposes, SID will stop such processing.
7. Right to complain: You have the right to complain about SID's processing of
your personal data. Such a complaint can be submitted to us at any time.
7. Revocation of consent
You can revoke one or more of your consents at any time by contacting SID, by
deleting your profile or by changing your settings on the Platforms.
If you revoke your consent, please note that in some cases you may not be able to
use Single.id.
8. Data processors and transfer of personal information outside the United Kingdom
1. SID may transfer certain personal data to data processors in countries outside
the United Kingdom. Transfer of personal data only takes place when a
necessary basis for transfer has been secured in accordance with local
Personal Data Regulations and where you have provided explicit consent.
9. Security and confidentiality
1. SID protects your personal data by implementing adequate technical and
organizational security measures.
2. SID treats your personal data confidentially. Selected employees at SID and
business partners are authorized to access data where necessary to solve
usability or technical problems. All of SID's employees and business partners
are subject to strict confidentiality requirements when processing personal
data.
10. Access to complaints
1. If you wish to complain about our processing or storage of your personal
data, please contact us at the points below 2.2 mentioned contact
information.
11. Changes to the Policy
1. SID reserves the right to change the Policy at any time and without prior
notice. Changes to the Policy come into force ten days after SID has informed
you about changes to the Policy by contacting you at the email address you
provided when creating your profile.
