Onaru Ventures Private Limited

At Pencilton we recognize that privacy is important. We respect your privacy and believe that we should clearly and transparently disclose our privacy practices to you as the user. The Pencilton mobile and desktop application, software, design, servers, data, user input, content, website located at www.pencilton.com (“Website”), and associated services (collectively “Services” or “App”) are owned and operated by Onaru Ventures Private Limited (“OVPL”). OVPL has adopted this Privacy Policy to inform you that it collects limited non-personal, personal and personally identifiable information, sensitive personal data or information when you use our Services and to explain how this personal and personally identifiable information is used by Pencilton services.

Our policy reflects our motto:
1. User data should be handled with utmost care.
2. We will not share or allow for accidental disclosure of user data.
3. We adhere to best in class industry standard data protection practices and shall have our systems audited by trusted third parties periodically.

It is also pertinent to inform everyone that OVPL is a technology provider to banks and is also a business correspondent facilitating marketing, sales, distribution of Pencilton co-branded prepaid instruments. All your KYC and financial transaction data is property of the bank by regulation. OVPL does not own such data and thereby cannot exercise any rights to share or sell the data to any other party.


1. Collection of Information
Pencilton App allows you to input information about you directly into the App and collects certain information programmatically when you register for Pencilton Services, when you install and use the App on your device, and when you use the Services as described in more detail below. Such information may contain personal, personally identifiable information or sensitive personal data or information.

A. Pencilton May Collect the Following Personally Identifiable Information (PII) from you
Personally, Identifiable Information (“PII”) is information that can be used to uniquely identify, contact, or locate a single person or can be used with other sources to uniquely identify a single individual. Pencilton collects PII from you when you voluntarily provide it to us, in instances in which you must provide such information to use features of the Services, and programmatically when you install the App, and when you visit websites of our partners. Pencilton may collect this PII from you through various channels, including, but not limited to, through your voluntary submission of information to the Services, through requests initiated by you through the Services, and through communication with third parties. Pencilton will collect sensitive personal information or data if and only if you voluntarily provide such information through Pencilton apps or services.
Our primary goals in collecting information is to provide you with the services made available through the Apps and websites, including, but not limited, to communicate with you, and to manage your registered user account, if you have one, and to improve the Services. Here is the PII that Pencilton may collect from you:

Any information that you voluntarily submit/input to the Services and information collected programmatically when you install the App, for example:
a. First and last name; b. Email address(es); c. Mobile and other phone number(s) d. Date of birth; e. Location; f. Contacts; g. Preferences; h. Your mobile device information, including, without limitation, device type, ID, model number, operating system, application, and related information; i. Payments you make using the App; j. Payment information, including credit/debit card or other payment account information; k. Any documents submitted as proof of identity or to fulfil any other requirements; l. Other required account or other information to utilize the service. m. Your MAC and/or IP address.

Where possible all information is collected and transmitted through secure connections. Your contact and payment information are always submitted, and payment is processed through a secure connection.

2. Use of Information

A. Pencilton Uses this PII and Non-PII Information in the Following Ways
Pencilton uses your PII and Non-PII to provide you with and bill you for the Services, to communicate with you, to identify and fix problems with the Services, to update you on changes to the Services, to communicate with you concerning your account, if applicable, and to update you on Pencilton’s services offered through the Services or the services of third parties. We use this information to make the Services easier for you to use, for example, by eliminating the need for you to repeatedly enter the same information. We also use this information for auditing, research and analysis purposes so that we are able to maintain, protect, and improve the Services and ensure the technical functioning of our network.
You further authorize the following uses:
1. Enable your use of the Services;
2. Process payment and verify payment information;
3. Improve algorithms;
4. Measure service usage;
5. Publish summaries online or offline;
6. Develop new features and services;
7. Contact and communicate with you, whether through email, phone, push notifications or messages within the Services;
8. Customize and/or tailor the Services and your user experience,
9. Display limited profile information like your name and profile picture, to other users and to display any other content you post to the Services which is meant for public consumption;
10. Advertise and provide you with information about products, benefits and services of Pencilton;
11. Provide you with information or services that may be of interest to you;
12. Transmit and process your information and actions within the Services;
13. Provide statistical information, and include you in the same, where applicable;
14. Provide you with technical service and support, including updates;
15. Understand your needs and requests;
16. Communicate promotions or other offers;
17. Prevent and detect illegal activities or violations of the End User License Agreement;
18. Protect OVPL’s rights and property and the same of our users;
19. Facilitate your use of the Services, its upgrades, or its replacements;
20. Provide the information to third parties performing services in support of our delivery of Services to you;
21. Personalize your experience with our Services;
22. Respond to legal requirements, exercise our legal rights or defend against legal claims, to protect our interests, fight fraud or illegal activity, to enforce our policies, or to protect third party rights, property, or safety.
OVPL may use analytics, attribution and reporting functions, and other services provided by third parties. We may share information from or about you with them so that they can perform their services as long as they comply with this Privacy Policy.

3. Storage of Information

Pencilton’s infrastructure consists of servers deployed at multiple datacenters that are owned and operated by our partners or us. All information collected in connection with the Services resides on this network of servers and/or on your device. Much of your information is stored on your device and is subject to the security and privacy policies of your device and storage providers. If Pencilton is using a vendor, all data storage by the vendor is consistent with the vendor’s policies. All data storage by Pencilton of your PII or Non-PII may be stored and processed on computers located outside of your country, and through your use of the Services you unequivocally consent to the processing and storage of your information outside of your own jurisdiction within. You understand and agree that Pencilton may continue to store your information after you cease use of the service or disable your use of, access to, or otherwise of the App. All your information is stored in encrypted format using commercially reasonable approaches.

In order to improve usability and experience Pencilton may store your private information on your personal device for subsequent retrieval and use for form submissions, payments and other transactions. Pencilton takes commercially reasonable care to encrypt this information on your device with passwords or other secrets supplied by you. Such information stored on your personal device is subject to security offered by your device, operating systems and other components. You understand and agree that Pencilton cannot be held responsible for any compromise of access to your personal device, for loss of information, theft or for any exploits or logic attacks on your device through malware or other software or hardware that is outside the control of Pencilton’s services.

Pencilton uses commercially reasonable and standard practices and technology to help prevent against the unauthorized access to, disclosure of, or alteration or destruction of your personal or personally identifiable information. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store PII and Non-PII. We restrict access to such information to our employees, contractors and agents who need to know that information in order to operate, develop or improve the Services. These individuals are bound by this Privacy Policy and other confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Though we undertake commercially reasonable efforts to protect your personal and personally identifiable information, no software or service is completely safe. Accordingly, you provide all such personal or personally identifiable information at your own risk.

4. Sharing Information

A. OVPL May Share your Information with Third Parties in the Following Circumstances
Where OVPL has obtained your consent, including when you choose to register a user account, use the Services, and otherwise share your information with Pencilton; where sharing or disclosure of your personal or personally identifiable information is necessary to provide you with the Services; where sharing or disclosure of your personal or personally identifiable information is necessary with OVPL’s parents, subsidiaries, successors, assigns, licensees, affiliates, or business partners (We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.); where OVPL has been purchased by a third party; where sharing or disclosure of your personal or personally identifiable information is necessary to respond to requests by government authorities; where your personal or personally identifiable information is demanded by a court order or subpoena; where sharing or disclosure of your personal or personally identifiable information is needed to protect the employees, independent contractors, officers, directors, members, users, or shareholders of OVPL; where sharing or disclosure of your personal or personally identifiable information is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty.

OVPL may share or disclose non-private, aggregated or otherwise Non-PII in the aggregate with third parties. This information does not identify you individually.

B. Your Choices

You may contact OVPL with any requests regarding your information, but OVPL reserves the right to act or not act upon such requests.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some of our features and services may not function properly if your cookies are disabled. You may decline to submit personal and personally identifiable information to any of our services, in which case we may not be able to provide those services to you.
If, at any time, you prefer not receive communications from OVPL, simply follow the unsubscribe options that may be available at the bottom of each such communication or contact us directly. We will make commercially reasonable efforts to implement your opt-out requests promptly, but you may still receive our emails for up to ten (10) business days as OVPL processes your request.

Where a data subject exercises a right under applicable privacy law, Pencilton will respond by taking any action required by the relevant privacy law, unless the request is obviously unfounded or excessive. Pencilton will take the relevant action within one month of receipt, unless a different time period is set by applicable privacy law.

Upon request by a data subject, Pencilton will provide data subjects with appropriate information on their personal data to confirm that it is accurate and up to date, as well as the right to request correction of their personal data.
When you use the Services, OVPL makes good faith efforts to provide you with access to your PII and to correct this data if it is inaccurate.

C. No-Spam Policy
We have a strict No-Spam Policy prohibiting the use of any data collected to send spam communications. We will not sell or share any contact information to third parties.

5. Changes to This Privacy Policy

Please note that this Privacy Policy may change from time to time. Pencilton will update on its website, mobile applications and other digital properties any changes in the Services and policies. In the event that Pencilton makes changes to this Privacy Policy, the effective date noted above will change and your continued use of the Services after a change in the effective date constitutes your manifestation of assent to the change. We will publish any changes to the privacy policy at least 30 days before they will become effective. If you do not agree to the change, you may not continue to use the Services.

6. Contact and Notices

If you have any questions or concerns about this Privacy Policy, please contact us by email at privacy@pencilton.com

All requests for information pursuant to this Privacy Policy or notices required must be sent via email to privacy@pencilton.com

7. Exclusions

This Privacy Policy does not apply to third party websites or applications that we may link or redirect you to during your use of our services, and you visit such third-party sites and apps at your own risk, consistent with their privacy policies, if any.