Privacy Policy

Tunnel Platforms Private Limited (“Tunnel,” “we,” “us,” or “our”) is owner of the website https://www.viatunnel.com/

We deeply value your privacy and are committed to safeguarding the confidentiality of your personal information. Please review this Privacy Policy to understand how we collect, use, process, disclose, and protect your  personal data collected through our website, products, services, marketing communications, and social media interactions (collectively referred to as our "Services") and how to exercise any rights you might have with respect to this information.

Please carefully read this Privacy Policy, which is an integral part of our Terms of Use, before using our Website and/or Services. If you do not agree with the Terms of Use and/or this Privacy Policy, you must refrain from using our Website and/or Services. By accessing or using our Services, you acknowledge your acceptance of the practices and policies outlined below. You also consent to our collection, use, and sharing of your personal data as described in this Privacy Policy.

Scope of this Privacy Policy

Tunnel as Controller: This Privacy Policy covers how we treat Personal Data that we collect when you access or use our Services in our role as a controller, such as when you visit our website, respond to our marketing, or register for our Services. Under privacy laws, "controllers" determine how and why to process personal data (and may also be called "businesses") and "processors" process personal data at the instruction of the controller with which they contract (and may also be called "service providers").

‍Tunnel as Processor: This Privacy Policy does not cover how we treat your Personal Data in our role as a processor to provide our products (such as Payments, Virtual Accounts, Ledgers and Compliance) to our customers. If you are a Tunnel customer, your use of our products and our use of your data as a processor is subject to your relevant agreement with Tunnel.

‍Clients of our Customers: If you are a client or end user of a Tunnel customer and have questions about privacy or security, please contact the customer directly, as our customer is responsible for their own privacy and data security practices. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.

‍Personnel of our Customers: If you work for a Tunnel customer, then your company administers its use of our products and sets its own policies for its users. Your company, as administrator, may access your accounts, restrict or terminate your access to our products, require you to reset your passwords, and take other actions related to your use of our products. Please contact your Tunnel organisation administrator for more information.

A. Your Consent

• Please note that by providing the Personal Information (as enumerated herein below) or by consenting to the provision of the Personal Information by your authorized representative, you provide your consent and authorize us to collect, store, use, process, disclose and protect Personal Information for the Legitimate Purposes (as defined below) and as stated in this Privacy Policy, the Agreement and as permitted or required by Applicable Law. Additionally, you acknowledge and provide consent that this information may be transferred to any third party for the purpose of providing you with Services through the Website, including jointly developed or marketed services, payment processing, order fulfillment, customer services, data analysis, information technology services, and other services that facilitate our provision of Services through the Website.

• This Privacy Policy shall be enforceable against you in the same manner as any other written agreement. By visiting or accessing the Site and voluntarily providing us with Personal Information (including Personal Data), you are consenting to our use of the Personal Information, in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you may refuse or withdraw your consent any time, or alternatively choose to not provide us with any Personal Information. Under such circumstances, your access to the Services we provide may be limited or we may be unable to render Services.

• Such an intimation to withdraw your consent can be sent to privacy@viatunnel.com

B. Personal Information

"Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations.

‍Personal Information of Children As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at privacy@viatunnel.com.

• Types of Personal Information We Collect

  This chart outlines the types of personal data we collect from you.

  • Profile or Contact Data:

    • First and last name;

    • Title and company affiliation;

    • Email Address; 

    • Phone number;

    • Business Address and Mailing Address

  • Online Identifiers

    • Account name 

    • Passwords

    • Email Address 

  • Payment Data (when paying for Tunnel or its Offerings)

    • Payment card type

    • Credit or debit card number (see "Payment Processors" below), 

    • Bank account information, 

    • Billing address, phone number, and email

  • Commercial Data

    • History of products purchased from Tunnel

  • Identity Data (for bank integrations)

    • Name 

    • Date of birth,

    • Tax ID or social security number, 

    • Bank account information, 

    • Address, 

    • Identity verification and Know Your Customer information (e.g. beneficial owner information)

  • Device/IP Data

    • IP address, 

    • Type of device/operating system/browser used to access the Offerings,

    • Language settings; 

    • Mobile device carrier

    • Radio/network information (e.g. wifi, LTE, 3G)

  • Audio or Video

    • Audio or video recordings of conversations or recordings between Tunnel support or customer success and customers, 

    • Screen recordings of use of sandbox accounts

  • Geolocation Data

    • IP-address based location information

  • Technical Information 

    • Internet or other electronic network activity information such as browsing/search history and IP address;

    • Data collected by cookies and similar technologies;

    • Device information such as device IDs, specifications, and operating system.

  • Other Identifying Information that You Voluntarily Choose to Provide

    • Identifying information in emails or letters you send us, 

    • customer support and customer success interactions

• How We Collect Your Personal Data

  We collect Personal Data about you from the following sources:

  • From You

    • When you provide such information directly to us.

    • When you register for or use our Services.

    • When you voluntarily provide information through responses to inquiries, surveys or questionnaires.

    • When you send us an email or otherwise contact us.

    • Automatically when you use the Services.

  • Through Cookies (defined in the Tracking Tools and Opt-Out section below).

    • If you use a location-enabled browser, we may receive information about your location.

  • Public Records

    • We collect certain information from public records and sources, such as social media platforms, publications, consumer reporting agencies, public databases and news sites.

  • Third Parties

    • Vendors: We may use analytics providers to analyze how you interact and engage with the Services or service providers may help us provide you our Services or related support. We may use vendors to obtain information to generate leads, create user profiles, or verify your identity or other information.

    • Partners: We may receive information from joint marketing partners or other business partners.

    • Parties you authorize, access, or authenticate: Some of our Services let you connect with other products that you use. When you authorise us to connect with your accounts with other products, we may receive certain Personal Data (e.g., contact data) that we use as described in this Privacy Policy.

• Purpose of Collection and Usage of Your Personal Information 

  • General Usage: For Providing, Customising and Improving the Services

    • Processing orders or other transactions; billing.

    • Establishing and maintaining your account for our Services.

    • Providing you with the Services or information you request.

    • Verifying your identity in compliance with sanctions and "Know Your Customer" laws

    • Meeting or fulfilling the reason you provided the information to us.

    • Providing support and assistance for the Services.

    • Improving the Services, including testing, research, internal analytics and product development.

    • Personalizing the Services, website content and communications based on your preferences.

    • Doing fraud protection, security and debugging.

    • Enabling customers to issue payment orders to Banks.

  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
  • Marketing the Services

    • Marketing and selling the Services.

    • Showing you advertisements, including interest-based or online behavioural advertising.

  • Corresponding with You

    • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Tunnel or the Services.

    • Sending emails and other communications according to your preferences or that display content that we think will interest you.

  • Meeting Legal Requirements and Enforcing Legal Terms

    • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.

    • Protecting the rights, property or safety of you, Tunnel, or another party.

    • Enforcing any agreements with you.

    • Responding to claims that any posting or other content violates third-party rights.

    • Resolving disputes.

    • Merger, acquisition, sale, divestiture, restructuring, reorganization, or asset transfer.

    • Transactions with businesses controlling, controlled by, or under common control with us;

  (Collectively referred to as “Legitimate Purposes”). We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

• Third Parties with whom We Share Your Personal Data

  We disclose your Personal Data to the categories of service providers and other parties listed in this section. For more information, please refer to the state-specific sections below.

  • Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

    • Hosting, technology, and communication providers.

    • Security and fraud prevention consultants.

    • Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of professional services they provide to us.

    • Support and customer service vendors.

    • Payment processors.

      • We use third party payment processors to process payment of your fees for our Services. Our payment processing partners collect your voluntarily-provided payment information necessary to process your payment.

      • To simplify the payment process, if you pay by credit card, we save the last four digits of your payment card, the expiration date of your payment card, the card type, your first and last name, your billing address, and a token identifier to match your information to your full payment card number, which is stored by the applicable payment processor. We do not store your full payment card number or your CVV2 number (the 3 to 4 digit security code on your card). We do not have access to your full payment card number stored by the applicable payment processor.

      • Please see the applicable payment processor's website to review their terms of service and privacy policies for information on their use and storage of your Personal Data.

  • Advertising Partners. These parties help us market our Services and provide you with other offers that may be of interest to you. They include:

    • Ad networks.

    • Marketing providers.

  • Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:

    • Companies that track how users found or were referred to the Services.

    • Companies that track how users interact with the Services.

  • Parties You Authorize, Access, or Authenticate. These parties partner with us in offering various products or integrations. They include:

    • Businesses that you have or seek a relationship with, and other integrated products.

    • Companies that we partner with to offer joint promotional offers or opportunities.

  • Bank Partners. We have bank partnerships that allow you to use our Services with your bank accounts. Depending on the integration, we may share Identity Data and other Personal Data with the bank to facilitate your use of your bank account with our Services and for security, compliance and related purposes.
  • Affiliates. We may share data with our current and future corporate affiliates for purposes consistent with this Privacy Policy.
  • Other Users. If you use our Services as a customer, we make available audit logs and usage data to other users on your company's account (such as IP address and certain associated activity) to allow our customers to observe logs or activity within their accounts.

C. Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under Meeting Legal Requirements and Enforcing Legal Terms in the Our Commercial or Business Purposes for Collecting Personal Data section above.

Business Transfers All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data We may create aggregated, de-identified or anonymised data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymised data and share it with third parties for our lawful business purposes, including to analyse, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

D. Tracking Tools and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, "Cookies") to enable our servers to recognise your web browser, tell us how and when you visit and use our Services, analyse trends, learn about our user base and operate and improve our Services. A cookie is an alpha-numeric identifier, which is small amount of data that is sent to a User’s browser from a web server and is eventually stored on a User’s computer hard drive. Cookies are a reliable mechanism to remember the activities of the User on the Website and help in improving Your experience on the Website.

Tunnel may set and access cookies on Your computer to track and store preferential information about You. We may gather information about You through cookie technology. For example, We may assign a cookie to You, to help better determine which of Tunnel’s news stories appeals to your interests. This anonymous information is maintained distinctly and is not linked to the User Information You submit to Us. The option of accepting cookies is up to You, however certain features of the Website including Content and the forms may not be accessible without accepting cookies. Please note that most Internet browsers will allow You to stop cookies from being stored on Your computer and to delete cookies stored on Your computer. If You choose to eliminate cookies, the full functionality of the Website may be impaired for You.

To browse anonymously, You may set Your browser to disable cookies or delete cookies. Most cookies are session cookies that are automatically deleted from Your hard drive when You close the browser. Additionally, You may encounter cookies or other similar devices on certain pages of the Website that are placed by third parties. We do not control the use of cookies by third parties and shall not be liable for any reason whatsoever for these third-party cookies.

We may use third party service providers to help Us analyse certain online activities. For example, these service providers may help us measure the performance of Our online campaigns or analyse visitor activity on the Website. We may permit these service providers to use cookies and other technologies to perform these services for Tunnel. We do not share any Personal Information with these third party service providers, and these service providers do not collect such information on Our behalf. Our third party service providers are required to comply fully with this Privacy Policy.

E. Opt-Out of Marketing Communications

You may opt-out of our marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at marketing@viatunnel.com. It may take about 7-10 days to process your request.

F. Data Security & Retention

Security
‍We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organisational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Retention
‍We retain Personal Data about you for as long as necessary to provide you with our Services. We will delete Personal Information based on a request received from you within a reasonable period and latest within thirty (30) days of receiving a deletion request. However, we may retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Data that is Not Personal Data
We may create aggregated, de-identified or anonymised data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymised data and share it with third parties for our lawful business purposes, including to analyse, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

G. Transfer of Information

• Your information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
• Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
• We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your data will take place to an organization or a country unless there are adequate controls in place including the security of your data.

H. Your Rights

• Right to Access: You can request from us:

  • Categories or specific pieces of Personal Information collected about you

  • Categories of sources from which we collected your Personal Information

  • Business or commercial purpose for which we collected your Personal Information

  • Categories of Third Parties with whom we sold, shared, or disclosed your Personal Information, including the categories of information and purposes for doing so.

• Right to Deletion: You can request us to delete any of your Personal Information we have collected, except when:

  • Required to retain the information for legal compliance, fraud prevention, or other lawful purposes

  • Used internally in a manner you authorized or reasonably expect as a consumer, such as completing a transaction.

• Right to Correct: You can request us to correct inaccurate Personal Information we hold about you. We will consider your request and may ask for supporting documentation. If we believe your request is fraudulent or unlikely to be accurate, we may deny it. context behavioral advertising purposes.

How to Exercise Your Rights:

If you wish to exercise your aforementioned rights, you can:
Email us at privacy@viatunnel.com
Complete our online request form

Please include your name, address, email, and a description of your request. We'll confirm receipt within 10 business days and may ask for identity verification. We'll process verified requests within 45 days, up to 90 days if necessary. If you have an online account, we'll respond via the account, otherwise, you can choose between mail and electronic delivery.

Changes to this Privacy Policy

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Tunnel website, by sending you an email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Conflict between this Privacy Policy and Local Laws and Regulations

When local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. In addition, the specific requirements of this Privacy Policy apply only when local laws and regulations permit.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• Website: https://www.viatunnel.com/

• Email: privacy@viatunnel.com