- Section 43A of the Information Technology Act, 2000 (“IT Act”);
- Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”); and
- Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
- What information We collect;
- How We collect and use that information;
- How You can provide information selectively, and how You can access and update this information; and
- How We process, share and protect Your information.
2. INFORMATION COLLECTED AND METHOD OF COLLECTION
We collect the following types of information about You, both through offline documentation that you may fill, as well as when You use Our Platform: Demographic Information, Behavioural Information, and Indirect Information, (as defined below, and collectively, “Information”). Additionally, We also collect Account Information and Personal Information (as defined below) from You. We collect Your Information and Account Information either directly from You through forms on the Platform or indirectly by using different technologies. We collect Personal Information (as defined below) only directly from you.
We may collect from You, information which is not unique to You and refers to selected population characteristics (“Demographic Information”) including age, gender, location and occupation. We may also collect information about how You use the Platform and information about Your mobile device and software including usage statistics, traffic data, Your IP address, browser and operating system type, domain names, access times, locations, Your previous orders and transactions including the product and pricing details, transaction information and payment and browsing history (“Behavioural Information”).
Your use of certain third party services on the Platform also requires Us to collect such information as is considered necessary for that purpose (“Indirect Information”). While We may collect Demographic Information, Behavioural Information and Indirect Information when You access or use Our Platform, We only collect Account Information and Personal Information from You, when You choose to use or avail of Our Optional Service. In order to avail of or use Our Optional Service, You are required to provide Us with Your details, including but not limited to: Your name; date of birth; mobile number; email address; PAN Number; password created by You, and details required for your KYC forms and the Account Opening form (collectively, “Account Information”).
The IT Act and the SPDI Rules regulate the collection, usage, retention and disclosure of personal information, which is defined under the SPDI Rules as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person. The SPDI Rules further define “Sensitive Personal Data or Information” (“SPDI”) of a person as personal information about that person relating to:
- financial information such as bank accounts, credit and debit card details or other payment instrument details;
- physical, physiological and mental health condition;
- sexual orientation;
- medical records and history;
- biometric information;
- any detail relating to the above clauses as provided to the body corporate for providing services; and
- any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise.
All Account Information and Personal Information is provided by You to Us voluntarily. Collection, use and disclosure of Personal Information requires Your express consent. By providing us with Personal Information, You are providing us with Your consent to Our use, collection and disclosure of the Personal Information. You may choose to not provide Us with any or all information included under Account Information and Profile Information, but in the event that You do not provide said information, We will be unable to provide You with Our Optional Service.
3. USE OF INFORMATION
We use Your Information for the following purposes:
- To operate and improve the Platform in order to foster a positive User experience and to improve our business as a whole;
- Analysing data, tracking trends, building algorithms, creating databases for rating systems, recommendations engines, etc.;
- For non-targeting reasons such as investment capping, compliance, billing, ad reporting or delivery, market research or product development purposes;
- To conduct audits and quality assessment procedures; and
- To analyse the use of Our resources, troubleshooting problems and improving Our Services, by using the information regarding Your mobile device and software.
- To provide Our Optional Service to You, including by creating, retaining and analysing your Investment Traits, Recommended Primers, Orders, Holdings and other relevant information;
To facilitate the opening of an account for the undertaking of any Transactions chosen by You, by:
- Obtaining Your KYC details from KYC Registration Agency, if You have a record with KYC Registration Agency, or obtaining any KYC details provided to Us by You to process your transaction account; and
- Communicating Your Account Information and Personal Information to the Broker, who will undertake the account opening process;
- To provide any and all information that may be required by Us or the Broker, from time to time, in compliance with existing legal norms and regulations, including but not limited to contact information, address and tax related information and any information required under existing or future KYC norms and laws or as may be deemed necessary to authenticate Your profile or any action taken using Your Account;
- To comply with applicable law;
- Contacting Users for offering new products or services;
- To respond to any queries that You may have, and to communicate information to You, including notifications of any promotions or alerts, any updates to the Platform, or the introduction of any future fees or charges that We may collect at the time for the provision of Our Services to You;
- To contact You from time to time to record Your valuable feedback on Our Services, as they currently stand, and/or any potential Services that may be offered in the future. (Collectively, the above constitute “the Purposes”).
If you wish to opt out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please email us at firstname.lastname@example.org.
4. DISCLOSURE OF THE INFORMATION
We disclose Your Information, Account Information or Personal Information, as the case may be to third parties in the manner specified below:
- Disclosing Your Information, Account Information and Personal Information to companies and individuals who are authorised by Us to perform functions, including Our Broker;
- We may share Your Information and Account Information with Our partners, affiliates, investors, stakeholders or potential associates in an anonymized and aggregate manner, so that they too may understand how Users use Our Platform, and enable Us to create a better overall experience for You;
- We also share aggregated anonymous information about Users with Our clients, partners, other Platform Users, and other third parties so that they may be aware of the nature and number of Users using the Platform, in order for them to be able to serve advertisements and other kinds of marketing information that may be relevant for You on Our Platform;
- We may disclose and transfer Your Information, Account Information and Personal Information to a third party who acquires, or may potentially acquire, Our business, whether such acquisition is by way of a merger, consolidation or purchase of all or a substantial portion of Our assets;
- We may transfer Information, Account Information and Personal Information to a third party, including persons outside India, to improve the Services; and
We will disclose Your Information, Account Information and Personal Information if legally required to do so, pursuant to an order from a governmental entity or in good faith. We will disclose the Information to:
- Conform to legal requirements or comply with legal process;
- Protect Our rights or property or Our affiliated companies;
- Prevent a crime or protect national security; or
- Protect the personal safety of Users or the public.
Such third parties may include:
- Our associates, affiliates or related entities;
- Any of our agents, contractors or third party service providers that process or will be processing Your Information, and relevant Account Information on Our behalf, including but not limited to those which provide administrative or other services to Us such as mailing houses, telecommunication companies, information technology companies and data centres; and
- Third parties, such as Our Broker, to whom disclosure by Us is for one or more of the Purposes and such third parties would in turn be collecting and processing Your Information, Account Information and Personal Information for one or more of the Purposes. Subject to applicable law, We may at Our sole discretion, transfer Personal Information to any other body corporate (as defined under the Information Technology Act, 2000) that ensures at least the same level of data protection as is provided by Us under the terms hereof, located in India or any other country. By using the Platform, You accept the terms hereof and You hereby consent to the storage and processing of Personal Information in any of the above locations.
5. THIRD PARTY LINKS
The Platform may include hyperlinks to various external websites, and may also include advertisements, and hyperlinks to applications, content or resources (“Third Party Links”). We have no control over such Third Party Links present on the Platform, which are provided by persons or companies other than Us. You acknowledge and agree that We are not responsible for any collection or disclosure of Your information by any external sites, applications, companies or persons thereof. The presence of any Third Party Links on our Platform, cannot be construed as a recommendation, endorsement or solicitation for the same, or any other material on or available via such Third Party Links.
You further acknowledge and agree that We are not liable for any loss or damage which may be incurred by You as a result of the collection and/or disclosure of Your information via Third Party Links, as a result of any reliance placed by You on the completeness, accuracy or existence of any advertising, products services, or other materials on, or available via such Third Party Links. This will include all transactions, and information transmitted therein, between You and any such third party sites or applications or resources, such transactions are strictly bi-partite. We shall not be liable for any disputes arising from or in connection with such transactions between You and the aforementioned third parties.
6. CHANGES TO YOUR INFORMATION
We reserve the right to verify and authenticate Your identity and Your Account Information and/or Your Personal Information in order to ensure accurate delivery of Services. Access to or correction, updating or deletion of Your Account Information or Personal Information may be denied or limited by Us if it would violate another person’s rights and/or is not otherwise permitted by applicable law.
7. SECURITY OF YOUR INFORMATION
We endeavour to maintain physical, technical and procedural safeguards that are appropriate to protect your Information against loss, misuse, copying, damage or modification and unauthorized access or disclosure. Some of the security measures adopted by Us are:
- We review Our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems; and
- We restrict access to Personal Information, to Our employees and agents who need to know that information in order to process it for Us, and who are subject to strict contractual confidentiality obligations, and may be disciplined or whose relationship with Us may terminate if they fail to meet these obligations.
Our Platform incorporates stringent security measures to protect the loss, misuse, and alteration of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. Once your information is in our possession we adhere to strict security guidelines, protecting it against unauthorized access.
No employee or administrator of the Company will have knowledge of Your Password. It is important for You to protect against unauthorized access to Your Password and Your mobile phone. Be sure to log off from the Platform when finished. We do not undertake any liability for any unauthorised use of Your Account and password. If You suspect any unauthorized use of Your Account, You must immediately notify Us by sending an email to email@example.com. You shall be liable to indemnify Us due to any loss suffered by Us due to such unauthorized use of Your Account or Password.
Further, We shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond Our reasonable control including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User, etc.
Retention of Information
We will also put in place measures such that Your Account Information and Personal Information, which is in Our possession or under Our control, is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the Purpose for which that Account Information or Personal Information were collected is no longer being served by the retention of such Account Information or Personal Information; and (ii) retention is no longer necessary for any other reason.
If You wish to cancel or delete Your account, or request that We no longer use Your Account Information and Personal Information to provide You Services, contact Us at firstname.lastname@example.org.
We, however, reserve the right to retain, store and use Your Information, Account Information or Personal Information or content for Our business purposes, whether such Information or Your Account has been deleted or not. After a period of time, Your data may be anonymized and aggregated, and then may be held by Us as long as necessary for Us to provide Our Services effectively, but Our use of the anonymized data will be solely for analytic purposes. Please note that Your withdrawal of consent or cancellation of Account may result in Us not being able to provide You with Our Services, or terminate any existing relationship that We may have with You. Please also note that uninstalling the Platform will not result in termination of Your use of the Platform or Services.
9. COOKIES AND OTHER TRACKING TECHNOLOGIES
We utilize Google Analytics to track user data on our platform. Google Analytics is a piece of software that consolidates user demographic and activity data to create anonymous high-level reports. No personally identifying data is included in this type of reporting. This tracking data allows us to understand our users’ behaviour and requirements. All our actions in this regard are governed by the Google Analytics Terms of Service. You can choose to opt out of the Google Analytics Advertising Features by changing Your Google account Ads Settings, Ad Settings for mobile apps, or any other available means.
You agree and undertake to indemnify Us in any suit or dispute by any third party arising out of disclosure of information by You to third parties either through Our Platform or otherwise and Your use and access of websites, applications and resources of third parties. We assume no liability for any actions of third parties with regard to Your Information, Account Information or Personal Information which You may have disclosed to such third parties.
13. GRIEVANCE OFFICER AND CONTACT INFORMATION
In accordance with the IT Act and rules made there under, the name and contact details of the Grievance Officer are provided below:
- Harsh Vardhan Singh
- PB-401, Alpine Eco Apartments, Doddanekundia, Bangalore - 560037