Indian Privacy policy
Last updated on: 01 August, 2024.
Tide Platform Private Limited (“Tide”, “We”, “us”, “our”, “Company”) (India Official address) recognizes the importance of safeguarding your privacy. We ask that all visitors of the Tide Website or users of the services and products available on the Tide Platform (also called “Members”) read this privacy policy (Privacy Policy) carefully as it applies to the processing of their personal information. It contains important information on who we are, how to contact us, how and why we collect, store, use, transfer/process and share personal information with respect to access and the use of our various products and services.
The Tide products and services are provided through different forms of digital or non digital mediums including but not limited to the Tide Website (http://www.tide.co), the Tide mobile application for Android, the Tide mobile website, web application (collectively called the “Tide Platform”). This Privacy Policy should be read alongside, and in addition to the Tide Membership T&Cs, and any separate product or service agreements you have accepted while accessing the products and services offered on the Tide Platform.
Whenever we refer to the ‘law’ under this Privacy Policy we are referring to all those applicable laws as amended from time to time in India, including but not limited to the laws which regulate the protection of digital personal data and privacy such as the Digital Personal Data Protection Act 2023. Where we have used but haven’t explained the meaning of a defined term in this Privacy Policy, that defined term has the same meaning as set out under the Tide Membership T&Cs. When we refer to ‘information’ or ‘data’ under this Privacy Policy, we refer to your personal information and/or sensitive personal information (described in the ‘Personal Information we collect’ section below).
By accessing the Tide Platform, you acknowledge and agree to us collecting, using, storing and processing your personal information in the way described in the Privacy Policy. If at any point in time, an individual/you provide data or other information about someone other than yourself, or on behalf of any entity or organisation or body corporate (“person”) you warrant that you have the necessary lawful ground, including, if applicable, that person’s consent to provide such information for the purpose specified. If you do not agree to the terms of the Privacy Policy, please do not use or access the Tide Platform.
1. Who we are
The Tide Platform is operated and managed by Tide Platform Private Limited, a company registered under the laws of India. We may share your data with our affiliates part of the Tide Group, either in whole or in part, for the administration of our business, the improvement of our products and services and for other purposes permitted by law.
For providing different products and services via the Tide Platform, we collect, process, use, store and are responsible for certain personal information about you. When we do so, we are regulated as a data fiduciary by the Digital Personal Data Protection Act 2023 and also by the Information Technology Act 2000 and any other applicable rules on data protection and privacy as amended from time to time.
2. Personal information we collect
Personal information means any information of a natural person (called a data principal) which can assist in identification of that person. Below is a list of types of information that we may collect and how we use the information when you access the Tide Platform, or use any of our products or services.
Type of personal information | Description | How we use the information |
Contact, personal and profile details | Your name, addresses, e-mail addresses, phone numbers, and other ways in which to contact you; identification details, such as date of birth, scans of ID documents, marital status, Aadhaar number, income details, your facial images or photographs and other information that you enter to use the Tide Platform and avail of any products or services | Managing our relationship with you or your business. Communicating with you about our and our business partners’ products and services. Delivering the Tide products and services to you, including to facilitate your use of the different Tide products and services via single sign-on. Developing and carrying out marketing or business development activities.
Identifying, investigating, reporting and preventing fraud, money laundering and other crime and to manage our company’s risk. Complying with laws and regulations. |
Transactional | Details about the transactions you carry out and the payments to and from your accounts with us including financial information, your bank account numbers, transaction amounts and references, currencies, time and date, payer and payee details, etc. | Making and managing customer payments. Delivering our and our business partners’ products and services. Managing fees, charges and interest due on customer accounts. To prevent fraud and to manage our company’s risk. Assessing your financial standing when reviewing applications for a credit product. Developing and improving the Tide products and services, our pricing for them and types of Members that may want to use them. Developing and carrying out marketing or business development activities. |
Contractual | Details about the products or services we provide to you | Carrying out our obligations arising from and exercising our rights set out in our contracts. Collecting and recovering money that is owed to us under any product or service offered via the Tide Platform. Operating our business in an efficient and proper way, including managing our financial position, business capability, planning, and audit. Developing and carrying out marketing or business development activities |
Locational | Data we get about where you are. This may come from the IP address assigned to your mobile phone or other device when you connect to the internet. It may also come from your zip code or the places where you have carried out any transactions using Tide Platform. | Delivering our and our business partners’ products and services. Identifying, investigating, reporting and preventing fraud, security breaches, money laundering and other criminal activity. |
Behavioural | Details about how you use products and services through the Tide Platform from us and other organisations, including through the use of cookies or other tracking software. | Studying how our Members use products and services from us and other organisations. Delivering more personalised user experiences to our Members. Developing and carrying out marketing or business development activities. Analytics, research and other forms of improving our products and services. Identifying, investigating, reporting and preventing fraud, security breaches, money laundering and other criminal activity. |
Technical | Details on the devices and technology you use, such as device identifiers, browser settings, etc. | Delivering our products and services to you. Delivering our and our business partners’ products and services. Identifying, investigating, reporting and preventing fraud, money laundering and other crime. Developing and carrying out marketing or business development activities. |
Communications | Any emails, calls or other communications you’ve sent to us or we’ve sent to you. What we learn about you from communications between us, including any feedback that we may receive from you. | Delivering our products and services to you. Carrying out marketing or business development activities. Investigating and responding to your enquiries, complaints and feedback. Analytics, research and other forms of improving our products and services. |
Public and third-party data | Details about you that are publicly available on the internet. We may also receive information about you from third-parties such as credit bureaus (see below for more information), payment services providers, social network companies, search engines, fraud-prevention and KYC service providers, etc. | Identifying, investigating, reporting and preventing fraud, money laundering and other crime. Determining the risks that applicants for a Tide account and Members may pose to Tide’s business and our other Members. Registering you with a Tide Membership account. Developing and carrying out marketing or business development activities. Investigating and responding to your enquiries, complaints and feedback. |
Your customer, business partner or employee data
| Any data that you provide to us about your employees, business partners, customers or other third-parties (e.g. name on an invoice, email address of a team member, etc.)
| When you have instructed us to do so and by virtue of your existing contractual relationship with us. Develop and improve our strategy for dealing with financial crime. Determine the risks that Members may pose to Tide’s business and our Members. |
Usage data | Other data about how you use our products and services | Studying how our Members use products and services from us and other organisations. Testing new products and services. Managing how we work with other companies that provide services to us and our Members. Developing and carrying out marketing or business development activities. Analytics, research and other forms of improving our products and services. |
Consents | Any permissions, consents or preferences that you give us on the Tide Platform or otherwise | So we know what your preferences are in regards to marketing and any other relevant data processing activities that you can opt-out of. Developing and carrying out marketing or business development activities. Exercising or defending legal claims. Complying with laws and regulations. Delivering more personalised user experiences to our Members. |
Documentary data and photos thereof | Documents or copies and photos thereof that you’ve made available to Tide when availing of the Tide products and services. This could include things like your passport, driver’s licence, photographs of business receipts or invoices, etc. | Delivering our products and services to you. Identifying, investigating, reporting and preventing fraud, money laundering and other crime. Complying with laws and regulations. |
3. Where we collect personal information from
We may collect personal information about you (or your business) from any of these sources:
Data you provide to us directly through the Tide Platform or otherwise.
Data we generate automatically when you use the products or services available on the Tide Platform
Data we collect from third parties, such as Tide business partners; service providers, including service providers that help us authenticate your identity; credit bureaus; fraud prevention agencies and others.
4. Who we share your personal information with
We will only disclose personal information with third parties for the reasons explained in this Privacy Policy or otherwise in the Tide Membership T&Cs. Below is a list of the types of third parties that we may share your personal information with.
4.1 Tide Group
We may share your personal information with other companies in the Tide Group, to the extent permitted by law, that help us with any of the purposes noted above or otherwise stated in the Tide Membership T&Cs.
4.2 Strategic partners
We will also share your data with our strategic partners who are integral in allowing us to offer the Tide products and services to Members. Below are some of our main partners.
Transcorp International Limited (“Transcorp”)
We collaborate with Transcorp to provide the co-branded e-money account under the Trancorp T&Cs (Transcorp prepaid card user agreement). Transcorp holds and processes your personal data as a data fiduciary to operate and manage your e-money bank account. Transcorp will process personal data such as your name, transactions, email address, selfie, and others in accordance with its Privacy Policy. You can read that Privacy Policy to understand how and why Transcorp processes your personal data and the details of any third-parties who will have access to that data.
Cashfree Payments India Private Limited (“Cashfree”)
Cashfree is a RBI-authorised payment aggregator who we partner with to facilitate outbound payments from your e-money bank account. Cashfree will process your transactional data as a data fiduciary, incl. personal data such as your names, date of birth, email address and phone number, etc. in accordance with its Privacy Policy. You can read that Privacy Policy to understand how and why Cashfree processes your personal data and the details of any third-parties who will have access to that data.
4.3 Tide Partners and third party links
We may include or offer products or services to you from other Tide partners on the Tide Platform. Those Partners will process your personal data as data fiduciaries independent from Tide and in accordance with their own privacy terms. Tide will make it clear when certain products or services on the Tide Platform are provided by Tide Partners and what personal data will be shared with such partners if you avail of those products and services. Tide Partners’ websites (including their service providers) have separate and independent privacy policies that apply and we (and any other Tide Group company; or any of our Tide company directors, officers, agents, contractors, or sub-contractors or workers) have no responsibility or liability for the content, activities and services relating to those linked websites. You can contact them for more information on how they may use your information. Similarly, the Tide Platform may host links to third party websites. We are not responsible for the content, activities or services related to such linked websites.
4.4 Legal Authorities/bodies and Courts
We may share your information with governmental authorities, courts or law enforcement officers who request or require any information. We will do this when:
disclosure is required to fulfil Tide’s obligation under laws in force in India to disclose such information to the state or any of its instrumentalities, insofar as such processing is in accordance with the provisions regarding disclosure of such information in the relevant law;
disclosure is required for Tide to comply with any judgement, decree or order issued under any law in force in India or to comply with judgments and orders relating to claims of a contractual or civil nature issued under laws outside in India;
4.5 Service providers
We may share your information with third party service providers to provide our services and products to you and to run our business. In most cases, those service providers will act as data processors to Tide and will process your data solely upon Tide’s instructions.They will be storing your data on Tide’s behalf for the duration specified in their contract with Tide and will not retain your data for longer than we retain it, unless necessary to comply with applicable laws, to resolve disputes or for other legitimate uses permitted by law.When those service providers are located outside India, we shall transfer data to them only if permitted by law and shall ensure they implement equivalent protection of your data compared to applicable data protection laws. This includes vendors, agents, sub-contractors, suppliers, consultants, advisers and other service providers.
4.6 General business
We may share your information with third parties to help grow and improve our business. This includes but not limited to:
Companies we have a joint venture or agreement to cooperate with
Organisations or individuals that introduce or refer you to us
Market researchers
Advisers who help us to come up with new ways of doing business
Advertisers and technology providers that you use (such as third-party websites you visit, social networks, and providers of apps and smart devices)
While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets, we may have to disclose our databases and information we have stored in the course of our business operations with the prospective counter-parties we are negotiating with
Other financial institutions to help prevent, detect and prosecute unlawful acts, money laundering or any kind of fraudulent/illegal behaviour.
5. Sharing anonymised data
We may share anonymised data with other companies, but only when it is converted so that no-one’s identity can be known or found out and is no longer considered to be personal information under the law (it is anonymised).
6. How long we keep your personal information
We will keep your personal information as long as it is necessary to provide you products and services on the Tide Platform (for the purposes listed in ‘Personal Information we collect”’). We shall retain and use the information collected as necessary to comply with our obligations under laws or contracts, resolve disputes or for other legitimate purposes to the extent permitted by law.
To ensure compliance with applicable laws, we will retain information even after you have terminated your account with us or stopped using the Tide Platform. We may also keep your contact information, communications and other details for fraud prevention, to resolve complaints or inquiries, for the exercise/defence of a legal claim or for providing evidence in legal proceedings.
We may continue to use the anonymised data aggregated or in combination with anonymised data of other users. We use this for analytics, research and other business purposes.
7. Cookies and other tracking technologies
We may use cookies, pixels, web beacons and similar tracking technologies to distinguish you from other users of the Tide Platform. This helps us to provide you with a good experience, and also allows us to improve our products or services. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device when you visit Tide Platform. Cookies send information back to the originating website on each subsequent visit, or to another website which recognises that cookie. Cookies also make it easier for you to log in and use the Tide Platform.
We may use the following cookies:
Strictly necessary cookies required for the operation of our products or services (including, for example, cookies that enable you to log into secure accounts and use interactive features);
Analytical/performance cookies that allow us to recognise and count the number of visitors and users and see how they use the products or services (e.g. (without limitation) to help us improve the way our products or services work or are provided, by ensuring that users are finding what they are looking for easily);
Functionality cookies to help us recognise you when you return to the Tide Platform (this enables us to e.g. (without limitation) personalise our content for you, greet you by name and remember your preferences, such as choice of language or region).
Targeting cookies to record your visit to the Tide Platform, the pages you have visited and the links you have followed. We may use this information to make our products and services and the information displayed on it, which we reasonably think is more relevant to your interests. We may also share this information with third parties for this purpose.
You can block or disable cookies by activating the setting on your website browser that allows you to refuse the setting of all or some cookies. All browsers provide tools that allow you to control how you handle cookies: accept, reject or delete them. These settings are normally accessed via the ‘settings’, ‘preferences’ or ‘options’ menu of the browser you are using, but you could also look for a ‘help’ function or contact the browser provider. However, if you set your browser settings to block or disable all cookies (including essential cookies) you may not be able to access all or parts of the Tide Platform for which we require the use of cookies.
8. Your rights
You will have the following rights with regard to Tide’s processing of your data and you can exercise those rights by writing to us at grievanceindia@tide.co. Please note that in order to discharge our obligations of a Data Fiduciary we may ask data principals to furnish information that is verifiably authentic when exercising the right to correction or erasure vis-a-vis Tide (Art. 15 (e) of the DPDPA) and that Tide is entitled and reserves its right not to respond to any false or frivolous grievance or complaints as per Art. 15 (d) of the DPDPA.
Right to Access Information About Personal Data: You have the right to obtain a summary of the information that Tide may have on you and obtain a list with the identities of all other Data Fiduciaries and Data Processors with whom your personal data has been shared by Tide, along with a description of the personal data we shared.
Right to correction and erasure of personal data.: In the event that any personal data provided by you is inaccurate, incomplete or outdated, then you have the right to provide us with the accurate, complete and up to date data, and have us correct, complete or update such data at our end without undue delay. Please ensure you notify us without undue delay of any changes to the personal data that you have provided to us by updating your details on the Tide Platform or by contacting us at the usual service support channels or the contact details provided in this Privacy Policy. You also have the right to erasure of your personal data unless Tide needs to retain it for a specified purpose or for compliance with a legal or regulatory obligation.
Right of Grievance: You have the right to have readily available means of grievance redressal provided by Tide related to any act or omission regarding the performance of our obligations to your personal data or the exercise of your rights under the provisions of the Digital Personal Data Protection Act. Our data grievance officer is accessible through email at grievanceindia@tide.co.
Right to Nominate: You have the right to nominate any other individual, who shall, in the event of your death or incapacity, exercise your rights in accordance with the Digital Personal Data Protection Act. You can contact us at indiasupport@tide.co to exercise this right and appoint a nominee.
9. Data protection practices
We employ adequate technical and organisational security measures to protect your personal information from being accidentally lost, used, changed, shared or accessed in a way it shouldn’t be.
We will limit access to your personal data to our employees, agents, contractors and other third parties who have a strict need to see it in order to perform their business functions. They will only process your personal data on a ‘need-to-know’ basis, pursuant to our instructions and they will keep your personal data confidential.
However, we do not guarantee that personal data will be completely protected. Any transmission of personal data by you is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Tide Platform, including through the illegal acts of third parties.
10. How to contact us
We have appointed a data grievance officer. Our data grievance officer is accessible through email at grievanceindia@tide.co. You can contact the officer confidentially by email to inquire about how we collect, store or use your information.
11. How to make a complaint to the Data Protection Board of India
If you are not happy with the outcome of a grievance processed by Tide you can submit a complaint to the Data Protection Board of India.Please be informed that you are entitled to raise a complaint with the Data Protection Board of India only after and not before you’ve exhausted the opportunity of redressing your grievance directly with Tide first.
12. Updates to this Privacy Policy
We may update this Privacy Policy from time to time. Please check back from time to time for updates. Continued use of our Tide Platform after any change/ amendment to this Privacy Policy shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.