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Date Updated: [June 1 2021] 

This privacy policy (“Policy”) explains our policy regarding the collection, use, disclosure  and transfer of your information by Lista (“we” or “us” or “our”), which operates the  website ("Site"), “Lista” (the “App”) available on Google Play  Store, iOS and other similar platforms and other services including but not limited to  recording credit/payment, communicating dues/balances via the site and application,  any mobile or internet connected device or otherwise (collectively the "Lista Service").  This Policy forms part and parcel of the Terms of Use for the Lista Services. Capitalized  terms which have been used here but are undefined shall have the same meaning as  attributed to them in the Terms of Use. Users (as defined hereinafter) are requested to  read this Policy in conjunction with the Terms of Use. 

The App/Site (i) provides an online digital ledger book / record book wherein the Users,  can record their ledger entries with their respective customers. Please note that  ‘Services’ would include any other future services we may provide or propose to  provide. 

As we update, improve and expand the Lista Service, this Policy may change, so please  refer back to it periodically. By accessing the Site, App or otherwise using the Lista  Services, you consent to the collection, storage, and use of the personal information  you provide (including any changes thereto as provided by you) for any of the services  that we offer. 

We respect the privacy of the users of the Lista Services (“Users” or “you”) and are  committed to reasonably protect it in all respects. The information about the User as collected by us is: (a) information supplied by Users and (b) information automatically  tracked while using a mobile device having Lista Services enabled (collectively referred  to as “Information”). By using Lista Services, you agree to this Policy. If you do not  agree with any term in this Policy, please do not use / avail of the Lista Services. 

Information supplied by users 

To avail certain Services on the Lista, Users are required to provide certain personal  information for the registration process which may include: a) their name, b) email  address, c) phone number, d) business name, e) business category. The Information as  supplied by the Users enables us to provide the Services and improve the Lista  Services and provide you the most user-friendly experience. In some cases / provision  of certain service(s) or utility(ies), we may require your contact address as well. Further,  upon downloading the App, Users are requested to share access to their contact list (as  stored on their mobile device on which the App is downloaded), so as to enable the  User to share payment/credit updates with his customers (who might be or might not be  Users). This contact list of the User is for the purposes of improving and enhancing the  User experience of the App. In an attempt to improve our Services, we may, from time to  time, collect any information (other than what is mentioned above) from Users through  App / Site. You may be assured that we do not share this data with any third party  except in accordance with the terms of this Policy. 

We may access a user's inventory of installed apps and treat this data as personal or  sensitive data subject to this Policy, secure transmission, and prominent disclosure  requirements of User. 

All Information is service dependent and we may use the Information to provide the  Services, maintain, protect, and improve the Lista Services, and for developing new  services.

We may also use your email address and phone number without further consent for  marketing, non-marketing or administrative purposes (such as notifying you of major  changes, for customer service purposes, providing information about updates to Lista  Services, billing, etc.). 

Any Information provided by you will not be considered as personal information if it is  freely available and/or accessible in the public domain or is not deemed as a personal  information under the applicable law. Further, any reviews, comments, messages, blogs  posted/uploaded/conveyed/communicated by Users on the public sections of the Site or  an application store (like the App Store or Play Store) becomes published content and is  not considered as personal information which is subject to this Policy. 

In case you choose to decline to submit Information on the Lista App/Site, we may not  be able to provide certain services on the App/Site to you. We will make reasonable  efforts to notify you of the same at the appropriate time. In any case, we will not be  liable and or responsible for the denial of certain services to you for due to not receiving  necessary Information from you. 


When you register with the Lista Services, we may (at our discretion) contact you from  time to time about updation of your Information. 

Information automatically tracked while using the App or Site 

Transaction Records: We store all your business transaction records in a cloud-based  environment using the services of third party infrastructure service providers. 

Customer Information: We store the contact information of your customers. We also  keep a log of all the credit/payment related communication to the customers.

Demographic and Related Information: We may reference other sources of  demographic and other information in order to provide you with more targeted  communications and promotions. We use Google Analytics, Firebase, Smartlook,  among others, to track the User behaviour on App/Site and improve our services. 

Log File Information: Our Servers automatically collect limited Information about your  device's connection to the internet, including your IP address, when you visit our Site or  use the App. We automatically receive and log Information from the App and/or your  browser including but not limited to IP address, your device or computer's name, and  your operating system, We may also collect log Information from your device, including  but not limited to your location, IP address, your device's name, device's serial number  or unique identification number (e.g. UDID on your iOS device, Android ID or ADID on  your Android Device), your device operating system, browser type and version, CPU  speed, and connection speed etc. 

Cookies: To improve the responsiveness of the Site for our Users, we may use  "cookies", or similar electronic tools to collect information to assign each visitor a  unique, random number as a User Identification (User ID) to understand the User's  individual interests using the identified computer. By continuing to visit the App/Site, you  are agreeing to the use of cookies and similar technologies for the purposes we  describe in this Policy. If you prefer not to receive cookies or web beacons, then you  should stop using Services, or consult your browsing and third party cookie settings. We  use cookies and other technologies for analysing and optimising our websites as well as  for marketing purposes. Our partners may also assign their own cookies to your  browser, a process that we do not control.

Link to third party sites/ad-servers 

The Site may include links to other websites such as advertisers, blogs, content  sponsorships, vendor services, social networks, etc. Such websites are governed by  their respective privacy policies, which are beyond our control. Once you leave our  servers (you can tell where you are by checking the URL in the location bar on your  browser), use of any information you provide is governed by the privacy policy of the  operator of the site you are visiting and we make no representation or warranty on how  your information is stored or used on third-party servers. That policy may differ from  ours. If you can't find the privacy policy of any of these sites via a link from the website's  homepage, you should contact the website directly for more information. 

Information sharing 

The Information (including personal information) collected may be shared with our  affiliates, and group companies to the extent required for our internal business and/or  administrative purposes and/or general corporate operations and to any third party  service providers including marketing partners, and the User hereby consents to the  same. We will take reasonable steps to ensure that these third-party service providers  are obligated to protect your personal information and are also subject to appropriate  confidentiality/non-disclosure obligations and they comply with the applicable provisions  of the data protection laws. These entities, with whom we share the Information, may  market to you as a result of such sharing unless you explicitly opt-out. 

The User explicitly consents that we may have access to your SMS, contacts in your  directory, location and device information and we may request you to provide your PAN  and Know-Your-Customer (KYC) details to check your eligibility for certain products/ services including but not limited to credit and payment products, etc., to enhance your  experience and provide you access to the services being offered by us, our affiliates or  other third party service providers (including lenders).

Further, the User also consents to sharing of Information (including sensitive personal  information) when it is requested or required by law or by any court or governmental  agency or authority to disclose, for the purpose of verification of identity, or for the  prevention, detection, investigation including cyber incidents, or for prosecution and  punishment of offences. These disclosures are made in good faith and belief that such  disclosure is reasonably necessary for enforcing the Terms of Use or for complying with  the applicable laws and regulations. No personal information of an individual User such  as name, phone number, email address, spends data, card details etc. would be shared  with any other User and/or third party unless explicitly approved by the concerned  individual User himself/herself. We may also present information related to credit  records, User spends, patterns and User data tracked by us only in the form of  aggregated statistics on data such as overall app usage by date, time, balances, etc.  within our App/Site or to our partners. 

By using the Lista Services and providing information to us, Users agree and consent to  the disclosure, transfer, storage, and processing of the personal information (including  the sensitive personal information) by us in Philippines and / or in other countries to its  affiliates, group companies and third parties. While our primary motive is to protect the  disclosure of personal information (except in accordance with the provisions of this  Policy) of Users, Users may note that countries where their Information may be stored,  may not have data protection laws similar to the countries where they are located. 

Accessing and updating personal information 

When Users use the Site (or any of its sub sites) / App, we make good faith efforts to  provide Users, as and when requested by Users, with access to their Information and  shall further ensure that any personal information or sensitive personal data or other  Information found to be inaccurate or deficient shall be corrected or amended as  feasible, subject to any requirement for such personal Information or sensitive personal  data or Information to be retained by law or for legitimate business purposes. We ask  individual Users to identify themselves and the Information requested to be accessed,  corrected or removed before processing such requests, and we may decline to process  requests that are unreasonably repetitive or systematic, require disproportionate  technical effort, jeopardize the privacy of others, or would be extremely impractical (for 

instance, requests concerning Information residing on backup tapes), or for which  access is not otherwise required. In any case, where we provide Information access and  correction, we perform this service free of charge, except if doing so would require a  disproportionate effort. Because of the way we maintain certain services, after you  delete your Information, residual copies may take a period of time before they are  deleted from our active servers and may remain in our backup systems. 

Information storage and backup 

From time to time, we take backup of your data on Lista on our cloud database. This is  done for the purpose of enabling Users to get their data back in case their phone's data  becomes unusable, or phone gets lost, or the User moves to a new phone device. We  also use this backup to provide useful insights and information related to their spends  such as weekly spends in a month, insights related to spend behaviour, etc., and to  provide information related to User spends, patterns and User data in the form of  aggregated and anonymized statistics on data such as User spends by category, date,  time, bank balances, etc. 


We shall keep User’s Information in our records till the period of time where we can  potentially offer the Lista Services to the Users. After such period of time where Lista  Services are no more relevant to a User, we remove all the Information pertaining to a  particular User from our records. 

Information security 

We take appropriate security measures to protect against unauthorized access to or  alteration, disclosure or destruction of data including accidental or intentional  manipulation, loss from access by unauthorised parties. These include internal reviews  of our data collection, storage and processing practices and security measures,  including appropriate encryption and physical security measures to guard against  unauthorized access to systems where we store personal data. All Information gathered  on the Lista is securely stored within the controlled database. Access to the servers is  password-protected and is strictly limited.

Our security measures are regularly reviewed and updated to reflect technological  developments. Regardless of where your personal information is transferred or stored,  we take all steps reasonably necessary to ensure that personal information is kept  secure, however, please understand that no transmission of data over the internet or  any other public network can be guaranteed to be 100% (one hundred percent) secure.  

We seek to ensure compliance with the requirements of the applicable data protection  laws to ensure the protection and preservation of the User’s privacy and personal  Information. We have physical, electronic, and procedural safeguards that comply with  the laws prevalent in specific jurisdiction to protect User’s Personal Information. By  accepting the terms of this Policy, you agree that the standards and practices being  implemented by us, are reasonable and sufficient for the protection of your personal  information. 

We will contact you regarding any breach of the security, confidentiality, or integrity of  your unencrypted electronically stored Personal Information to you via email or any  other feasible manner in the most expedient time possible and without unreasonable  delay, insofar as consistent with the legitimate needs of law enforcement and will  undertake all measures necessary to determine the scope of the breach and restore the  reasonable integrity of the data system. 


Purpose of Data Processing 

We will only collect and process Personal Information about you where we have lawful  basis to do so. Our primary purpose in collecting your information, including Personal  Information from you is to deliver the personalized Lista and its various features. Please  note that should you choose to not provide us consent to collect your information,  including Personal Information, we may not be able to perform the contract with you.  Where we refer to 'perform the contract' we mean the Terms of Use applicable to your  use of the Lista Service, which means that you may either not be able to access certain features of the Lista Service or we may not be able to provide you the Lista Service in  entirety.


For example, we use your information where we need the Personal Information to  perform the contract with you (for example, to provide the Platform or our services to  you) so as to: 

• Register you on our Platform 

• Provide you with customer or technical support including addressing support  queries related to, but not limited to, payment processing, or to diagnose any  problems with our servers etc. 

• Send you transactional emails/SMS or to provide you with information, direct  marketing, online and offline advertising and other materials regarding products,  services and other offers from time to time in connection with the Lista Service or  its parent, subsidiary and affiliated companies ("Platform Entities") and its joint  ventures. 

• Determine your geographic location, to provide you localized content including  advertisements, personalized recommendations, allow you to continue watching/ using previous content at another time, and to determine your Internet service  provider to troubleshoot a technical issue, and help us quickly and efficiently  respond to inquiries and requests; 

• To provide you with a personalised service and experience; we do this by linking  some or all of your Personal Information such as transactions done with Lista  with your activity on our Platform across all your devices and associating and  storing this information with a unique platform generated identifier that is  generated for each user (guest as well as registered user). When a guest user  subsequently registers and creates an account, the information and data relating  to such user's past activities gets added to and associated to the registered  account. 

• In other contexts, if the processing of your Personal Information is subject to the  EU General Data Protection Regulation, we use your Personal Information where  the processing is in our legitimate interests and not overridden by your  fundamental rights and freedoms (for example, our direct marketing activities in  accordance with your preferences) such as to:Display or target advertisements  on the Platform based on your registration or profile information, location and/or  your activity on the Platform across all your streaming devices (including inferred 

information through usage and log data) which is associated with your device  advertising identifier (IDFA, GAID etc) – this is typically referred to as 'interest based advertising'. We also display contextual advertisements on the Platform  

but these are not targeted to any particular user and does not make use of any  information that personally identifies you or precisely locates you (contextual  advertising is advertising which we target based on the content being viewed, for  example if you are watching a particular sporting event we may serve adverts of  companies or products related to that particular sport or the age-group most  likely to be watching). 

• Research, analyze and understand our audience and what content and  advertising they may view, watch or otherwise engage with, in order to improve  our service (including our user interface experiences and security features);  evaluate your eligibility for certain types of offers, products or services and  market such products or services to you; to perform analytics and conduct  customer research, including general market research or surveying our  customers' needs and opinions on specific issues, generating sales and traffic  patterns, and to analyze advertising effectiveness, both on an anonymous basis  (e.g., by aggregating data) or on an individual basis (if legally permissible), in  combination with other information collected from tracking technologies and  aggregate it with information collected from other Users using our Platform, to  attempt to provide you with the Services and a better experience on the Platform.  For example, one of the ways we use this information is to count the number of  times an advert or other content is viewed because this might be the metric by  which our advertisers pay us. This information is compiled and analyzed on an  aggregated basis. 

• Allow you to participate in interactive features such as Game play events on the  Platform, providing you with relevant gameplay experience, determine and  declaring winners and providing you with prizes. 

• Analyse and measure how effective our advertising is by determining which  media sources should be paid for delivering a desired action e.g. users who  install our application or subscribe (also known as 'attribution'), so that we pay for  demonstrated value and don't overspend. 

We will use your Personal Information with your explicit consent as follows:

• When you agree to share your precise location based on GPS data, we will  combine this information with other information that you provide to us on the Lista  Service to provide personalised content and advertisements with better accuracy  basis your geographic location e.g. you may see more regional content  recommendations or advertisements for local establishments, when you share  your precise location based on GPS data; 

• When you agree to share information pertaining to the applications frequently  used by you on your device, we will combine this information with other  information that you provide to us on the Lista Service, to display advertisements  that are more relevant to your interest areas 

Or otherwise whenever the law requires us to get your permission or where we have  stated we may seek your permission in this Privacy Notice. In some contexts, we use  your Personal Information where we have a legal obligation to do so or to protect your  vital interests or those of another person: 

• Prevent, detect and investigate potentially prohibited or illegal activities, including  fraud, and enforcing our terms (such as determining free trial eligibility);

• Confirming your identity if you are exercising legal rights; 

• Notify you about changes in the Terms of Use or in this Privacy Notice;

• Carry out our obligations and enforce our rights arising from any contracts  entered into between you and us/our distributor. 

When you access or use the Services or send any data, query, request or  communication to us via our Support email, you understand that you are communicating  with us electronically, and that we may respond via electronic means from us, such as  by email. 

Revocation of consent 

A User can revoke his consent to the processing of his personal information at any time  with effect for the future. Please note that withdrawing consent does not affect our right 

to continue to collect, use and disclose personal information where such collection, use  and disclose without consent is permitted or required under applicable laws. 


We may alter our Policy from time to time to incorporate necessary changes in  technology, applicable law or any other variant. In any case, we reserve the right to  change (at any point of time) the terms of this Policy or the Terms of Use. Any changes  we make will be effective immediately on notice, which we may give by posting the new  policy on the Site. Your use of the Lista Services after such notice will be deemed  acceptance of such changes. We may also make reasonable efforts to inform you via  electronic mail. In any case, you are advised to review this Policy periodically on the  Site to ensure that you are aware of the latest version. 


Questions/Grievance Redressal 

In the event you have any grievance relating to the processing of Information provided  by you, you may write to us on our Facebook Page: 


In case any personal information is shared by you with us, which is not requested by us  during registration, (whether mandatorily or optionally), we will not be liable for any  information security breach or disclosure in relation to such information. If you have any  questions regarding this Policy or the protection of your personal information, please  contact our data protection officer/grievance officer.

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