1.REGULATORY FRAMEWORK, SCOPE & APPLICABILITY
The information collected from you by the Company may constitute ‘personal information’ or ‘sensitive personal data or information’ as defined under the Data Security Rules. Personal Information is defined under the Data Security Rules to mean 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 Data Security Rules further define Sensitive Personal Data or Information of a person to mean such personal information about that person which consists of information relating to: (i) passwords; (ii) financial information such as bank accounts, credit and debit card details or other payment instrument details; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) biometric information; (vii) any detail relating to the above clauses as provided to body corporates for providing services; and (viii) any of the information received under the above clauses by body corporates for processing, stored or processed under lawful contract or otherwise.
The Website and our Services are designed and intended for use by adults. If you are a minor, please do not share your personal data or information. If we discover that we have collected information from a minor, we will delete that information as soon as possible. In no event shall the Company be liable for any information provided by a minor. We may use your personal information to carry out age verification checks and enforce any age restrictions applicable to the User Account.
3.COLLECTION OF PERSONAL INFORMATION
When you access or use the Website, the Services and the Company Sites, we collect information about you through various means as described below:
Information Provided to Company: When you register with us (or create an account on the Website and use the Services), we collect information that you provide voluntarily during your registration or creation and use of your User Account. This includes information such as your name, gender, the name of your company, in the event you are accessing the Website on behalf of your organisation, your designation and capacity, your username and password, your email address, postal address, phone number and other relevant information. We may collect and store any information you provide us when you use our Services, including when you: (i) add information on a web form; (ii) add, edit or update your account information; (iii) contact us for support or other offerings; (iv) participate in community discussions, chats, or dispute resolutions; (v) correspond with us regarding the Website or the Services; (vi) respond to a survey conducted by us; (vii) register for a promotion provided by us; (viii) request certain features (e.g., newsletters, updates, or other products); (ix) submit feedback to us; and/or (x) submit a resume and apply for or save jobs or send invitations. The Company in this regard collects information that identifies you.The information collected from the users is to make the basic compliance adherence as defined under the SEBI (Investment Advisers) Regulations, 2013, like KYC, Risk Profiling, etc.
Contacting the Company: We may also collect information about you from other sources, such as through your contact with us, including our customer support team, your interactions with other Users. Additionally, for quality and training purposes or for our own protection, we may monitor or record telephone conversations with you or anyone acting on your behalf. By communicating with us, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.
Authentication and Fraud Detection: In order to help protect you from fraud and misuse of your personal information, we may collect information about you and your interactions with our Services. We may also evaluate your computer, mobile phone or other access device to identify any malicious software or activity.
Company Emails:Emails we send you may include a technology that tells us whether you have received or opened the email or clicked a link in the email. If you do not want us to collect this information from the Company marketing emails, you can opt out of receiving the Company marketing emails. Where permissible under applicable law, we may also include web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics purposes.
Company Online Advertising: Company advertises online in a variety of ways, including displaying Company ads to you on other companies' websites and apps. We collect information such as which ads are displayed, which ads are clicked on, and on where the ad was displayed. We may share site usage information with trusted third parties (e.g. advertisers, advertising agencies, advertising networks, data exchanges, etc.) in order to offer you tailored content, including more relevant advertising for products and services which may be of interest to you. These third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to help us deliver customized content and advertising to you when you visit Services or Third Party Sites.
Buttons, Tools & Content from Other Companies: The Website/Company Sites may include buttons, tools, or content that link to other companies’ services, such as Facebook, Twitter, Instagram, LinkedIn, Google Plus and Pinterest. We may collect information about your use of these features. In addition, when you see or interact with these buttons, tools, or content, or view a web page on the Website or our app containing them, some information from your browser may automatically be sent to the other company, in accordance with the terms and conditions of such other company.
Information from You about Others:If we offer a referral option and you choose to use it to invite a friend to use the Services, we will ask you for your friend’s email address and other personal details. You must make sure your friend has consented before you provide us with your friend’s email address and personal details. We will automatically send your friend emails and other communications inviting your friend to visit the Company Sites. We store this information only to send emails and other communications to your friend and track the success of our referral program.
Location Information: When we provide our Services and/or other offers, we may ask you for, access, or track geo-location-based information from your mobile or other electronic device while downloading or using the Company mobile app or functionality. If you choose to engage with these services, we will receive certain information about your location, which may include country, state, city, or more specific location information, in order to provide you with the requested services including geographically relevant features, offers, applications, and application recommendations.
Cookies and Related Tracking Technologies: The Website and/or the Company Sites use persistent and session cookies and other similar technologies to offer you a personalised experience and to remember your browsing preferences, including your log in details and choice of language. Cookies are stored primarily to ensure that in the event you return to the Website, it shall personalise your browsing, including, enabling you to be logged on the Website automatically. This information may, where permitted by applicable law, also be combined with other information we hold about you. The cookies are uniquely assigned to you and can only be accessed by your web page server in our domain. You can disable our cookies or all cookies through your browser settings. Upon the beginning of each of your visits to the Website, the Website also provides the choice to turn off all cookies which are not strictly necessary for the provision of Services. Please be advised that disabling cookies through either method may impact many of the Website’s features. In addition to cookies, we and/or our third-party advertising partners may use technologies that help us better manage and analyse content
Your Personal Information is maintained by the Company in electronic form on its equipment, and on the equipment of its employees, agents, representatives and sub-contractors. Such information may also be converted to physical form from time to time. The Company takes necessary precautions to protect your personal information both online and off-line, and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of the Company’s business.
The Company makes all information of a User accessible to its officers, employees, consultants, agents, representatives, sub-contractors, service providers and third parties only on a need-to-know basis and binds all of them to strict confidentiality obligations
Part of the functionality of the Company is assisting the Company’s service providers to maintain and organise such information for rendering services, including the Services. The Company may, therefore, retain and submit all such records and information to the Company’s service providers who request access to such information.
Notwithstanding the above, the Company is not responsible for the confidentiality, security or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, the Company shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of the Company 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.
5.USAGE OF PERSONAL INFORMATION
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information: (i) for the provision of seamless and efficient Services to you, customised in accordance with User preference, i.e. for performing our obligations towards you; (ii) for business management, accounting and auditing purposes; (iii) to verify your identity; (iv) to enable you to access the Website and use the Services; (v) to provide you with necessary details pertaining to your User Account and your license to use the Services, including, sending notifications for termination of contract; (vi) to accept payments from you for using the Services, and to process and complete your transactions on the Website and to send you related information, including purchase confirmation and invoices; (vii) to send transactional communications, including responses to your comments, questions and requests; (viii) to contact you, through voice call, text messages, or emails, as authorised by you, under the Terms and Conditions; (ix) to do such activities for which you have explicitly given us consent; (x) to comply with applicable laws, rules and regulations, as updated from time to time; (xi) to inform you about our new products and/or services, when we have reasons to believe that you would be genuinely interested in such products and/or services; (xii) to enhance and customise our customer care services to suit your need; (xiii) to respond to your queries or service requests and for resolution of the same; (xiv) to send you technical notices, updates, security alerts, and support and administrative messages; (xv) to advertise, promote, or market our products and services and to undertake all other types of business development activities; (xvi) to comply with applicable security standards and to prevent money laundering and/or fraud or any attempt thereof; (xvii) to detect, prevent or remedy any breach of the Terms and Conditions; (xviii) to meet our legitimate interests (or those of a third party) when your interests and fundamental rights do not override those interests; (xix) to offer you personalised discounts on Services and updates; (xx) to perform research, business and/or operational analysis; (xxi) to protect your (or someone else’s) interest; (xxii) to deal with legal disputes, if any; (xxiii) to provide, maintain or improve our products and services; (xxiv) to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; (xxv) to conduct data analytics studies to review and better understand customer satisfaction and needs; (xxvi) to generate internal reports about our User base and service usage patterns, analyse the accuracy, effectiveness and popularity of the Services; (xxvii) to track User activity and behaviour pattern on the Website; and/or (xxviii) to protect the public interest or for official purposes, if formally requested by any investigative or other governmental authority of India. We may also use your personal information to generate charts, presentations, reports, logs, or other documents about, inter alia, our User base, service usage patterns, analysis of the accuracy, effectiveness and popularity of the Services for marketing, investment or other external purposes. However, in case of such external use, we shall ensure to anonymise the personal information provided by you. You hereby give your express consent to us for using your personal information for this purpose.
We may contact you as necessary to enforce or change our policies, applicable law, or any agreement we may have with you. When contacting you via phone, to reach you as efficiently as possible we may use and you consent to receive, auto-dialled or pre-recorded calls and text messages. Where applicable and permitted by law, you may decline to receive certain communications.
We implement reasonable security practices to store your data accurately, confidentially and securely. The term for which we shall be retaining your personal information depends solely on the nature of the information. We shall retain your personal information only for such period of time as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
The Company may, at any time, delete your information, including but not limited to, your personal information, without any prior notice to you. Upon the expiry of your license to use the Services or deactivation and/or termination of your User Account, the Company shall have the right to, immediately and permanently, delete all stored messages, emails, contents and all other records of your User Account without any notice.
Except to the extent provided herein, we will destroy your personal information upon the fulfilment of its purpose. We may, however, retain your personal information for: (i) accounting purposes for such time period as is prescribed under applicable law; and (ii) for legal purposes till the completion of statutory limitation for bringing any suit, if any.
7.SHARING OF INFORMATION COLLECTED
Processing of Transactions: We share information, including personal information, with our officers, employees, consultants, agents, representatives, sub-contractors, service providers and business partners to enable them to undertake, perform and deliver the Services purchased by you.
Third Party Service Providers: We share information, including personal information, with our third-party service providers that we use to: (a) to host and maintain the Website, (b) for application development, back-up, storage, payment processing, analytics, marketing and front or back end development and support; and (c) for audits, web analysis and other services required to enable seamless provision of Services. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us. We forbid the third party service providers from using your personal data for their marketing purposes or for any purposes other than for the provision of services to us. Please note that third party service providers have their own privacy policies, and the Company is not responsible for their actions, including their information protection practices.
Business Transaction: We may share your information in connection with any corporate restructuring, including a merger, demerger, amalgamation, reorganisation, sale of some or all of the Company’s assets, a change in control transaction or a financing or acquisition of all or a portion of our business by another company.
Consent: We may share your information in any other circumstances where we have your express consent.
Company Affiliates: We may share your information among the affiliates of Company so that we can better provide better services that are relevant to you as well as generally to provide the services as applicable.
Publishers and Advertisers: We may share the information with our publishers and advertisers to aid in their understanding of how Users are using our apps and engaging with ads.
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. Any processing of your data by third party shall only be done by treating the information collected from you confidentially, legally and securely.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised manner. In addition, we have limited the access to your personal information to those who have a need to know.
It is necessary for the Users to keep their personal information and their password confidential. The Users must not share their usernames and passwords with anyone to prevent unauthorised use of their personal information. You shall, at all times, be responsible for the protection of and the disclosure of your username and password. We shall, in no way, be liable for disclosure of your username and/or password, or your personal information, in the event of any unauthorised access of your User Account. In the event of such unauthorised usage, you shall notify us immediately.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9.ACCESSING AND DELETING YOUR INFORMATION & OPTING OUT
You may, under applicable law, have the right to access, correct, update or delete the personal information the Company holds about you. In order to exercise your rights, to the extent permitted and required of the Company under applicable law, please contact us at firstname.lastname@example.org
We respect your communication preferences, if you no longer wish to receive notifications via our application, you can adjust your preferences. If you prefer not to receive ads that are tailored to your interests, you can opt out by writing to us at email@example.com at any time.
The Company may use your information to contact you in the future to inform you about the services the Company believes will be of interest to you. If the Company does so, each communication it sends to you will contain instructions permitting you to "opt-out" of receiving future communications. In addition, if at any time you wish not to receive any future communications or wish to have your name deleted from our mailing lists, please contact us at firstname.lastname@example.org.
If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send us an email at email@example.com
The Website may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (Interactive Areas). You should be aware that any information that you post in the Interactive Areas might be read, collected, and used by others who access it. To request removal of your personal information from an Interactive Area, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
11. LINKS TO THIRD PARTY SITES AND SERVICES
If a User uses the Services or accesses the Company Sites after a notice of change has been sent to such User or published on the Company Websites, such User hereby provides his/her/its consent to the changed terms.
13. CHILDREN'S AND MINOR'S PRIVACY
The Website and our Services are designed and intended for use by adults. If we discover that we have collected information from a minor, we will delete that information as soon as possible.
We strongly encourage parents and guardians to supervise the online activities of their minors to help provide a child-friendly online environment and prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Services are not intended for use by minors, we respect the privacy of minors who may inadvertently use the internet or the mobile application.
We shall not be liable for disclosure of your username and password and you shall be solely responsible for protecting your username and password, at all times. You shall choose your password carefully and shall not use other User’s username and password to log in to the Website at any point of time. You shall be solely liable for any unauthorised use of the Website through your User Account. In the event of such unauthorised usage, you shall notify us immediately and reset your password accordingly
The Company hereby expressly disclaims any implied warranties imputed by the laws of any jurisdiction. The Company considers itself and intends to be subject to the jurisdiction only of the courts of the Mumbai in India. If the User does not agree with any of the disclaimers herein, the user must refrain from accessing any of the pages on the Website. The Company reserves the right to make changes to the Website and these disclaimers, terms, and conditions at any time.
There are risks associated with utilizing internet, email and short messaging system (SMS) based information and research dissemination services. Users are advised to understand that the services can fail due to failure of hardware, software, and Internet connection. While we ensure that the messages are delivered in time to the users Mobile Network, the delivery of these messages to the user's mobile phone/handset is the responsibility of the user's Mobile Network. SMS may be delayed and/or not delivered to the user's mobile phone/handset on certain occasions, owing to technical reasons that can only be addressed by the user's Mobile Network, and the Company or any group companies associated with it and/or its employees cannot be held responsible for the same.
Pattern Effects Labs Private Limited.