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    PRIVACY POLICY

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    MITRAMONEY TECHNOLOGY SOLUTIONS PRIVATE LIMITED PRIVACY POLICY

    Your Privacy is extremely important to MitraMoney Technology Solutions Private Limited. This Privacy Policy covers how we collect, store, display, use and transfer your personal information.

    This document is an electronic record in terms of the Information Technology Act, 2000 and the Rules thereunder as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signature.

    By browsing and/or signing up to avail any of the Services of MitraMoney Technology olutionss Private Limited (“MitraMoney”/”Us”/”We”/”Our” as the context may require), all Users (“User”/ “you”/”your”) including you as a Registered User agree and acknowledge that you have read, understood and consented to the terms of this policy. If you do not agree to the terms contained herein, we request you not to proceed with the use of the Services. This document shall for convenience be hereinafter referred to as “Privacy Policy”.

    When you use any of the Services offered by MitraMoney as a Registered User, you agree and understand that you will be required to share personal information and personally identifiable information with us in connection with the services offered to you and in this regard you agree to be bound by this Privacy Policy. This Privacy Policy comprehensively sets out the nature of information we collect as well as the mode, manner and purposes for which we will collect each category of information covered herein. This document also sets out the consents and authorizations we require from you in order to provide you the Services.

    Definitions:

    Personal information” as used under this Privacy Policy shall mean and include name, contact details and user identifiers. Further, this Privacy Policy sets out the manner and conditions subject to which we use Personally Identifiable Information you share with Us in the normal course of providing the services to you. For purpose of clarity, “Personally Identifiable Information” shall mean information such as your financial information, investment transaction details, nominee details and KYC details as well as user identifier details, if any.

    “Non-personal information” This includes data that, on its own, may not be directly associated to a single individual. Some examples of non-personal information include device identifier, location information, internet bandwidth, mobile device model.

    “General User” Includes an individual who is just visiting and exploring the Services and has not submitted any Personal Information to MitraMoney.

    “Registered User/ Customer” When you voluntarily provide any of your Personal Information requesting to avail a service or Services from MitraMoney, you become a Registered User and customer of MitraMoney.

    1. Information We Collect:
      1. As a General User: If you are just visiting and exploring the Services, MitraMoney will not seek any information from you to establish your identity. However, MitraMoney may collect information in connection with your activity, for example the icons you click, average time spent, your internet protocol address, your device identifier, location information, internet bandwidth, mobile device model, browser plug-ins, and cookies that may identify your browser.
      2. As a Registered User: In connection with your request for Services and for the purpose of approving your request and delivering Services to you, MitraMoney collects information such as your name, photograph, gender, income, your location, physical address, mobile number, PAN details, your age, bank account details, personal e-mail address and such other statutorily mandated identification documents including personally identifiable information to enable Us to process your KYC compliance, Investment Transaction and/or anti money laundering compliance as a precondition to approving your service requests as well as for the purposes more fully covered in Clause 5 below.
    1. Classification of Information we Collect:
      1. When you avail the Services of MitraMoney as customer of MitraMoney, We collect and store your personal information and financial transaction information. All this information helps us provide the Services seamlessly and provide additional benefits/ features that meet your requirements. The kind of information We collect also helps Us customize the Services to make your experience safer and easier. However, We assure you that We use your Personal Information only for the designated purposes as set out in Clause 5 of the Privacy Policy and only as per consents set out in Clause 10.
      2. The categories of information We collect from Our Registered Users are as follows:
        • Know Your Customer (KYC) Information and Verification: We as a distributor of mutual funds are required as per the applicable law to validate, process and/or share your KYC Information with other intermediaries, Regulated Entities (REs) or AMCs. In terms of the aforesaid, you consent and authorize MitraMoney and its affiliates and group companies which provide services to MitraMoney to collect KYC documents as mandated by relevant regulatory authorities to help Us process your financial product subscription requests and share them with the mutual fund house/ AMC or other recognized intermediaries. MitraMoney may engage with third party service providers for effectively rendering the Services you may opt for from time to time. For this purpose, you authorize Us to carry out video and/or other digital and offline modes of verification for KYC compliance.
        • Investment Transaction & Payment Information: Once you have researched and shortlisted a particular financial product and the financial institution offering such product through the functionality provided as part of the Services, you consent and authorize MitraMoney to use the investment details, KYC documents, financial details, nominee details and other Personal information you share with Us for the purpose of processing your subscription forms and ensuring your subscription requests reach the concerned financial institution for further processing and approval. For this purpose, You authorize MitraMoney to share these details with the third party financial institutions who offer financial products as part of the Services.
        • Information collected to prevent fraud: We may either from you or from third parties including your bank, collect information about you for the purpose of verifying and authenticating an investment transaction request you place with Us in order to prevent suspicious transactions. This may also include contacting you directly to collect additional information to authenticate a transaction request, validate a standing instruction for a Systematic Investment Plan or confirm a payment made via the Services.
        • Your Usage Pattern Information: We may also collect and store your non-personal information pertaining to your real time activity while browsing through or availing Our Services. We will keep a track of transaction history and average transaction values to improve your usage experience. As a Registered User, you also agree to be part of online surveys which We conduct to understand you and your financial requirements better so that We can serve you better and customize your service experience. These surveys will not ask you to share any information that will identify you personally and would only be queries in connection with your general preferences as an investor.
        • Device Information: We may collect information about your internet enabled device for the purpose of technical support and fixing bugs and for providing the Services to you.
        • Your Communications with Us: When you send an e-mail or send other communications to Us including via e-mail or Our customer care (as notified from time to time), you authorize us to retain those communication records in order to process your enquiries, respond to your requests and improve the quality of Services.
    1. Who collects Personal Information:
      1. In order to provide you the Services, We, Our affiliates and group companies will get access to your personal information for the purposes of facilitating KYC documentation and electronic processing of financial transactions. We assure you that the affiliates and group companies will hold and use your personal information securely and will deploy all reasonable administrative and technical safeguards to protect the integrity of your information.
      2. The affiliates and group companies involved in the collection of a Registered User’s personal information shall for all purposes fall within the meaning of “person on behalf of body corporate” as contemplated under Rule 4 of the Information Technology (reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.
    1. Sharing and Transmission of Personal Information:
      1. As a Registered User, you consent to MitraMoney sharing your personal information and other details with third party financial institutions with which MitraMoney has relationships with for the purpose of processing your financial product subscription requests placed with Us and ensuring that these requests reach the relevant financial institution whose product you have opted for. You also consent to MitraMoney sharing your KYC Information with KYC Registration Agencies (“KRAs”) and other government bodies for the purpose of complying with applicable law as well as meeting the Know Your Customer (KYC) requirements of the financial institutions whose financial product or financial services you opt through the Services.
      2. We and/ or our affiliates may from time to time offer other products and services to you and in this connection, you agree and understand that We will use your personal information including KYC documents, but excluding investment transaction information in connection with other services should you choose to opt for them. These entities may market their offerings to you by reaching out to you unless you specifically opt-out from such communications by communicating your opt-out through the Customer dashboard made available as part of the Services.
      3. If you are an existing customer of any of Our affiliates and are already using their Services or have already previously signed up with MitraMoney for a particular service, your previous consent shall continue to be effective and We shall use your existing information for processing your request for all MitraMoney Services.
      4. We assure you that We will not transfer or share any of your Personally Identifiable Information such as your passwords, access credentials, credit card information, financial transaction details processed through MitraMoney, with any of our affiliates unless you expressly consent to the same basis a request made to you by MitraMoney in terms of this Privacy Policy or to comply with applicable law. We assure you that our collection, storage and use of your Personally Identifiable Information you share with Us in connection with the service shall be used by Us only for the purpose of serving your interest or protecting you from any risks. All use of Personally Identifiable Information will be in compliance with the requirements under the Information Technology Act, 2000 and rules made thereunder.
      5. In the event that MitraMoney plans to merge with or be acquired by another business entity, We will be required to share some or whole of your personal information with the newly formed entity. We may also have to share/ transfer/ your personal information in the context of a corporate re-organization, amalgamation or a restructuring event. However, we assure you and undertake that the new entity will continue to be bound by the terms of this Privacy Policy as regards handling and securing your personal information.
    1. Purposes for which MitraMoney Uses your Personal Information:
      1. MitraMoney covenants that it uses your personal information only for purposes as identified in this Privacy Policy and to comply with applicable law.
      2. MitraMoney uses the personal information and transaction information of a Registered User including products opted for the following primary purposes:
        • To conduct the KYC compliance process as a mandatory prerequisite for any financial transaction as per the requirements of SEBI and other regulatory bodies;
        • To perform compliance checks as well as maintain internal records to handle audits and other requests from the financial institution to whose financial products you have subscribed to;
        • To fill in and process your investment enrolment forms and forward them to the relevant financial institution and intermediaries for processing; or
        • To process your requests in relation to other products or services that MitraMoney may offer to you from time to time.
      3. To the extent that MitraMoney uses your personal information to market other offerings to you, we provide you the facility to opt out of such use and the opt out can be done via a tab which will be available in your customer account dashboard.
      4. We also use your personal information to resolve disputes, troubleshoot problems, help promote a safe Service, collect/ pay money on your behalf under your instruction, measure consumer interest in our current services or future offerings, customize the Services or help in tackling fraud. For the purpose of improving the Services, MitraMoney collects and analyses demographic and profile data about all Registered Users.
      5. MitraMoney retains the right to communicate with you (via e-mail, postal service/courier or mobile messaging services/display banners on the internet and/or in third-party websites) either directly or through third-party vendors), when operational or regulatory requirements require us to do so.
      6. MitraMoney will disclose your personal information including your investment details and transaction history with third parties if the same is required to comply with applicable law or if the disclosure is required as per the directions of a court of law, Securities and Exchange Board of India or other legal process. We may also disclose personal information to Law Enforcement Authorities and officers, or to other third parties in the event We are of the view that such disclosure is necessary to enforce our Terms and Conditions or this Privacy Policy or in response to a court notice or advertisement.
    1. Data Security Provision:
      1. We have stringent security measures in place to protect against the loss, misuse, or alteration of information under Our control. We assure you a secure mode of access to your Services, We always adhere to strict security guidelines in order to protect Personally Identifiable Information once it reaches our servers and ensure that it is protected against any kind of unauthorized access subject to the condition that you are also expected to keep the username and passwords, if any safe and not share it with any third party. If you do share your access credentials, it shall be your sole responsibility and liability in case of any misuse since MitraMoney does not share this information with any third party under any circumstances. It shall be your responsibility to intimate Us in case of any actual or suspected compromise to your personal and investment details. You agree and understand that your right to use and avail services from MitraMoney through the unique customer account created for you is non-transferable and non-assignable. Any delegation done to third parties to access your customer account shall be at your sole risk and responsibility.
    1. Restrictions and Prohibited Uses:
      1. During the course of your use of the Services including while using the Services, you agree not to, by any means (including hacking, cracking or defacing any portion of the Site) indulge in illegal or unauthorized activities.
      2. You shall not during the course of your use of the Services restrict or inhibit any authorized user from using or accessing the Services.
      3. You shall not carry out or attempt to do any action with the intent of harvesting or collecting information about other users or accessing accounts of other users without their authorization.
      4. You shall not frame” or “mirror” or reverse engineer any part of the Services or applications where the Services are hosted or engage in any kind of spamming or flooding.
      5. You are prohibited from transmitting any software or other materials that contain any virus, time bomb, or other harmful or disruptive component.
      6. You shall use the Services “as is” without changing or attempting to make changes to any proprietary content or remove any copyright, trademark or other proprietary rights notices contained therein.
      7. You shall not use or access the Services through devices or programmes that can retrieve, index, data mine or in any way reproduce or circumvent the navigational structure or any other component including the customer dashboard that MitraMoney provides you to access Services.
    1. Disclaimers of Third Party Links:
      1. The Services may include links to other websites or applications. Such websites or applications 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 application, you are visiting. That policy may differ from ours and you are requested to review those policies or seek access to the policies from the domain owner before proceeding to use those applications or websites.
      2. We use third-party advertising companies to serve ads when you visit Our applications. These companies may have a privacy policy different from our Privacy policy. You are requested to review the policy before proceeding to use the services from third-party advertising companies. We do not provide any Personal Information to third party websites/ advertisers/ ad- servers without your consent, except in the circumstances mentioned in below clause.
    1. Opting Out Rights:
      1. We provide all users with the opportunity to opt-out of receiving any of our Services or non-essential (promotional, marketing-related) communications from Us, after setting up the Services. If you want to remove your contact information from all our lists and newsletters or discontinue any our Services, please unsubscribe or intimate us in writing.
      2. If you cease using our Services, your personally identifiable information will not be used by us or shared with third parties except for the following purposes: (i) We may delete these records over time if permitted or required by law. (ii) In order to meet Our reporting and auditing obligations and to detect, deter as well as prevent fraud or other misconduct on Our systems. The information will be retained in Our systems for so long as the aforesaid purposes remains a business necessity.
    1. Consent:
      1. By using the MitraMoney Services either currently offered or those that maybe offered from time to time and/ or by providing your information, you consent to the collection and use and sharing of the information by MitraMoney or its affiliates in accordance with this Privacy Policy.
    1. Control over your Personal Information:
      1. You can review and update your information or delete any information about you by logging in to your Customer Account. You may also place a request for updating or deleting your information by writing to Us. However, you understand that the deletion of certain classes of information may impact your future use of the Services and may even result in total suspension of the Services if the deleted information is of a category that is considered mandatory under applicable law, guidelines and regulations. If you terminate your Services, We will ensure that your personal information is deleted from Our systems subject only to the exception that We may retain copies of your information to comply with applicable law or to respond to a demand by a court or statutory authority.

    2. Cookie Policy:
      1. A “cookie” is a small piece of information stored by a web server on a web browser, so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given user. We place both permanent and temporary cookies in your internet enabled device’s hard drive. The cookies do not contain any of your personally identifiable information. We use cookies on certain pages of the Services to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. We offer certain features that are only available through the use of a “cookie”. We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Services and you may be required to re-enter your password more frequently during a session.

    3. Changes to Policy:
      1. We reserve the right, at our sole discretion, to change, modify, add or remove portions of the Privacy Policy at any time without any prior written notice to you. It is your responsibility to review the Privacy Policy periodically for updates / changes. Your continued use of Our Services following the posting of changes will mean that you accept and agree to the revisions. We may however endeavour to notify you of changes through a written e-mail communication or a written message to your registered mobile number.
    1. Grievance Redressal and raising concerns:
      1. As mandated under the Information Technology Act, 2000 and rules made thereunder, the details and contact information of the Grievance Officer appointed by MitraMoney to address your data related concerns is as follows:
        • Name: Vidhushi Aggarwal
        • E-mail: [email protected]Mitra.money
        • Address- Block 8, Flat – 902. My Home Vihanga, Financial District Hyderabad -500032
    1. Applicability of this Policy:
      1. This policy will come into force on the date of publication. You are requested to review changes made to the policy from time to time and by continued use of MitraMoney’s services, you are deemed to have read and understood the modified terms. MitraMoney will endeavour to notify you of any changes within a reasonable time through a communication sent to your registered e-mail address.