- Scope and Application
- The terms “we/us/our” shall refer to Fundfolio Fintech Private Limited, having our registered office at 39/2475-B1, Suite#346, LR Towers, SJRRA 104, S Janatha Rd, Palarivattom, Kochi Ernakulam KL 682025 IN (“Company”), and the terms “you/your” shall refer to the users and any other persons accessing or seeking to use the Platform (defined below).
- We are committed to ensure that your privacy is protected to all possible, reasonable and commercial extent, as your privacy and data protection is of the utmost importance to us.
- Collection of information
- For the purposes of rendering our Services through the Platform, we may collect your information from various channels, including, but not limited to, voluntary submission of information from your end in furtherance of the access or usage of the Platform, through requests initiated by you towards the Services and through communications.
- You represent that the information you provide from time to time is and shall be correct, current and updated and that you have all the rights, permissions and consents to provide such information. Your providing the information to us, and our consequential storage, collection, usage, transfer, access or processing of the same shall not be in violation of any third-party agreements, laws, judgments, orders or decrees.
- Types of Information collected by us
- Personally Identifiable Information (“PII”)
- PII, as used in information security and privacy laws, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.
- We may collect and retain certain PII including without limitation your name, age, gender, telephone number, mailing address, permanent and current residential addresses, email address, history of your transactions with us (if you are a subscriber), etc. These PII are essential for rendering our Services to you. We may also use this information to customize our Services based on such information as provided by you.
- We also collect any information exchanged by you with us in the form of written communication, responses to emails, feedback provided, participation in discussions, etc.
- You have the right to request to discontinue our use of your PII. To withdraw your consent to our collection and processing of your information in future, you may do so by sending an email to [email protected] or specifically informing us that you are withdrawing your consent towards our use of your PII.
- Non-Personal Information (NPI)
- If we do combine NPI with PII, then the combined information will be treated as PII for as long as it remains combined.
- We use various technologies and/or third-party tools to collect NPI, including without limitation:
- Web beacon or other technologies: We often use web beacon in conjunction with cookies, to enhance our Services on a number of pages of the Platform. A non-identifiable notice of a visitor’s visit to a page on the Platform is generated and recorded. Such notice may be processed by us or our third-party associates. To disable some of these features, you may disable cookies in your web browser’s settings. Web beacon and other technologies will still detect visits to these pages, but the notices they generate are disregarded and cannot be associated with other non-identifiable cookie information.
- Google Analytics or other tools: Our Platform uses certain third-party tools (including but not limited to Google Analytics), in order to evaluate your use of our Platform, and to provide other services relating to the Platform activity, among other things.
- We may also collect other non-specific information to provide you better access to our Services each time, such as preferences and interests and other non-personal details via the Platform, any application form or email or any other medium. We may also store and publish such information to assist us in making the Platform better and easier to use.
- Additionally, we may collect and use technical data and related information, including but not limited to technical information about your device, system and application software, and peripherals, that is gathered periodically, to facilitate the provision of software updates and other Services to you. We may use this information, among other things, to improve our Services or technologies.
- Information Usage and Sharing
- Please note that we do not and will not trade or sell your PII in any manner with your prior consent or as mentioned below.
- We are both a data controller and a data processor.
- We may share your PII with third parties in the following circumstances:
- We have a good faith belief that access, use, preservation or disclosure of such PII is reasonably necessary to: (i) satisfy any applicable law, regulation, legal process or enforceable governmental request including to law enforcement and in response to a court order, (ii) detect, prevent, or otherwise address fraud, technical or security issues, (iii) enforce applicable Policies of the Platform, which may be further extended to investigation of potential violations thereof, or (iv) protect against harm to our rights, safety or property, our users or the public as required or permitted by law;
- To protect ourselves against third-party claims;
- Is necessary for performance of a contract between you and us;
- To any member of Our related or group companies including Our subsidiaries, Our ultimate holding company and its subsidiaries, as the case may be.
- In the event that We sell or buy any business or assets, we may disclose Your Personal Information to the prospective seller or buyer of such business or assets. User, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate re-organization. corporate divestitures, mergers, acquisition, sale of business and/or dissolution.
- We may partner with third-party entities to provide you with additional services related to our business or other programs that involve third parties, and this impliedly authorizes us to share your PII with those parties. A third party’s use of your information is bound by contracts and agreements between us and the third party. We only share information reasonably needed to provide the additional services/benefits. By sharing information with us, you agree that we are not liable or responsible for the actions or inactions of third parties;
- We may disclose/share information to third-parties who support our business, such as those providing technical infrastructure services, analysing how our services are used, measuring the effectiveness of advertisements, providing customer support and business support services, facilitating payments, or conducting research and surveys, and the information will be used for the limited purposes of such services received by us.
- We may also provide your information to our partners, associates, advertisers, service providers or other third parties to provide, advertise or market their legitimate products and/or services which may be of your interest. You will have the choice to ‘opt out’ of such marketing or promotional communications at your will.
- Links to/from Third-Party Websites
- The Platform may contain links to third-party websites, products, and services. Information collected by third parties, which may include without limitation information such as location data or contact details, is governed by the privacy practices undertaken by such third parties. We encourage you to learn about the privacy practices of those third parties. We expressly assert that we cannot be responsible for these practices.
- We may have presence on social networking websites including but not limited to LinkedIn, Facebook, Twitter, YouTube, Telegram and blogs which are promotional and business initiatives to attract, engage and connect to a larger group of people. The domain links contained therein may either direct you to our Platform or request your participation by way of feedback, suggestions, etc. We, in this regard, fully disclaim any liability(ies) or claim(s), which may arise by use/misuse of your feedback, suggestions, views, etc. on any of the aforementioned networking websites or blogs, by any third party whether or not known to us.
- Information Security & Retention
- We take precautions including without limitation, administrative, technical and physical measures to safeguard your personal information against loss, misuse or theft, as well as against destruction, alteration, disclosure and unauthorized access.
- For this purpose, we adopt internal reviews of the 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 your PII. Specifically, while we will ensure our best efforts to protect your information in line with commercially reasonable efforts and general industry standards; however, we do not represent, warrant, or guarantee that your information will be protected against unauthorized access, loss, misuse, or alterations beyond our reasonable control.
- When you use our Services or post on the Platform, some of the PII you share is visible to other users and can be read, collected, or used by them. You are responsible for such PII you choose to submit in these instances. For example, if you list your name and email address on the Platform while providing comments or reviews, that information may be public. Further, you are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer/mobile systems, and you agree to accept responsibility for all activities that occur under your account or password.
- We may share your information with third parties for the purposes mentioned in Clause 5 under confidentiality arrangements in connection with our Services, which inter alia provides that such third parties may not further disclose the information.
- A “Force Majeure Event” shall mean any event that is beyond our reasonable control and shall include, without limitation, sabotage, fire, flood, earthquakes, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorised access to computer, computer system or computer network, computer crashes, breach of security and encryption (provided it is beyond our reasonable commercial control), power or electricity failure or unavailability of adequate power or electricity. While we will endeavour to take all reasonable and appropriate steps to keep secure any PII which we hold about you and prevent unauthorized access, you acknowledge that the internet or computer networks are not fully secure and that we cannot provide any absolute assurance regarding the security of your PII. Please exercise reasonable caution when determining what information you disclose via the Platform.
- You understand and agree that we may continue to store your information after you cease to use the Services or disable your use of, or access to the Services or the Platform. Please note that we shall not use, share and/or disclose your PII with third parties, after you cease to use our Services or disable your use of, or access to the Services or the Platform, unless required by law to do so. NPI will be retained indefinitely, and we may continue to use, share and/or disclose your NPI in furtherance of our Policies.
- You acknowledge and agree that we reserve the right to remove or edit content, refuse Services, terminate accounts, or cancel plans at our sole discretion.
- Your rights relating to the Information
- The right to be informed – this means anyone processing your personal information must make clear what they are processing, why, and who else the information may be passed to. 8.2 The right of access – this is your right to see what information is held about you by us. 8.3 The right to rectification – this is your right to have your information corrected or amended if what is held is incorrect in some way.
- The right to erasure – this is your right to ask for your personal information to be deleted under certain circumstances. This applies if the personal information is no longer required for the purposes it was collected for, or your consent for the processing of that information has been withdrawn, or the personal information has been unlawfully processed.
- The right to object – this is your right to object to further processing of your information which is inconsistent with the primary purpose for which it was collected.
- Payment Related Details
- We use secure networks for processing online payments for subscriptions. We do not store your credit card/debit card details or your internet banking details on our servers. The payment data is encrypted through the 3rd party payment gateway when processing your payments. Your purchase transaction data is only used as long as is necessary to complete your purchase transaction and is not saved thereafter.
- The payment gateway adopted by us adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, and American Express. PCI-DSS requirements will help ensure the secure handling of payment data information by the Platform.
- Payment gateways and other payment transaction processors will have their own privacy policies with respect to the information you are required to provide to them and we are required to provide to them for your payment-related transactions, and as such, those details will be governed by their privacy policies.
- Operating System Permissions
- Mobile platforms (Android and iOS) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. Upon becoming operational, the iOS platform will alert you the first time our App wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that our App seeks before you first use the App, and your use of the App constitutes your consent. Sometimes these permissions require more explanation than the platforms themselves provide, and the permissions we request will change over time.
- Android permissions:
Device & App history: We need your device permission to get information about your device, like OS name, OS version, mobile network, hardware model, preferred language, installed apps etc. Based on these inputs, we intend to optimize your overall experience by understanding your preferences and by using OS specific capabilities.
Identity: This permission enables us to know about details of your account(s) on your mobile device. We may use this info to auto-fill your email address and provide a typing free in-channel experience. It also allows facilitating your login.
Contacts: If you allow us to access your contacts, it enables us to make it easy to get referred by your friends and also send across referral links to your friends. This information will be stored on our servers and synced from your phone.
Location: If you allow us access to your location, we will be in a position to provide you a personalized experience based on your location.
Wi-Fi: When you allow us the permission to detect your Wi-Fi connection, we optimize your experience based on the connection speed.
Device ID & call information: This permission is used to detect your Android ID through which we can uniquely identify users.
- In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess it promptly. Depending on the outcome of our assessment, we will make the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you.
Grievance Officer Name: Abdul Khader
Email address: [email protected].com
- The Grievance Officer can be contacted between 10am to 5pm from Monday to Friday except on public holidays.
- Governing Law
- We are incorporated in, and based out of the Republic of India, and we are duty bound to abide by Indian laws. We may not have complied with some privacy laws of other countries and further represent to be unaware of such other legal requirements.
- Questions and Contact Information