Last Updated: 1st January 2023

Privacy Policy

Finplify Application is developed by Finplify Technologies Private Limited, a company incorporated under the Companies Act, 1956 with its registered office at No 2, 3rd A Cross, Kanakadasa Layout, Lingrajpuram, Bangalore-560084, India. This Policy describes how Finplify and its Affiliates/Entities/Subsidiaries/Associates (collectively Finplify, we, our, us” as the context may require) collect, store, use and otherwise process your Personal Information through Finplify website, Finplify Application, m-site, notifications or any other medium used by Finplify to provide its services to you (hereinafter referred to as the “Platform”).

By downloading and using Finplify, visiting the Finplify website, providing your information or availing our product/services, you expressly agree to be bound by this Privacy Policy (“Policy”) and the applicable service/product terms and conditions. We value the trust you place in us and respect your privacy, maintaining the highest standards for secure transactions and protection of your personal information.

This Privacy Policy is published and shall be construed in accordance with the provisions of Indian laws and regulations including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under the Information Technology Act, 2000, the Aadhaar Act, 2016 and its Amendments, including the Aadhaar Regulations; that require publishing of the privacy policy for collection, use, storage, transfer, disclosure of Personal Information. Personal Information means and includes all information that can be linked to a specific individual and also includes Sensitive Personal Information (all Personal Information which requires heightened data protection measures due to its sensitive and personal nature), both, hereinafter referred to as “Personal Information”, excluding any information that is freely available or accessible in public domain. Please note, we do not offer any product/service under our Platform outside India. If you do not agree with this Privacy Policy, please do not use or access our Platform.

Interpretation and Definitions


Interpretation


The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.


Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application means the software program provided by the Company downloaded by You on any electronic device, named Finplify.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Finplify Technologies Pvt Ltd.
Country refers to India
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Application.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.


Collecting and Using Your Personal Data

We may collect your Personal Information when you use our services or Platform or otherwise interact with us during the course of our relationship. We collect Personal Information which is relevant and absolutely necessary for providing the services requested by you and to continually improve the Finplify Platform.

Personal and Sensitive Personal Information collected includes but not limited to:

  • Name, age, gender, photo, address, phone number, e-mail id, your contacts and nominee details.
  • PAN card number, KYC related information such as videos or other online/ offline verification documents as mandated by relevant regulatory authorities, your business-related information.
  • Aadhaar information including Aadhaar number or Virtual ID for the purposes of e-KYC authentication with the Unique Identification Authority of India (UIDAI). Note that submission of Aadhaar information is not mandatory for e-KYC authentication, you can also use other types of information, such as your PAN or GST number.
  • OTP sent to you by your bank or Finplify Application.
  • Balance, transaction history and value, bank account details, wallet balance, investment details and transactions, service or transaction related communication, part of your card details for smooth transaction using Finplify or any of the services.
  • Your device details such as device identifier, internet bandwidth, mobile device model, browser plug-ins, and cookies or similar technologies that may identify your browser/Finplify Application and plug-ins, and time spent, IP address and location.

Information may be collected at various stages of your usage of the Finplify Platform such as:

  • visiting Finplify Platform
  • registering on Finplify Platform as an “user” or “merchant” or any other relationship that may be governed by terms and conditions listed on Finplify Platform.
  • transacting or attempting to transact on Finplify Platform.
  • accessing links, e-mails, chat conversations, feedbacks, notifications sent or owned by Finplify Platform and if you opt to participate in our occasional surveys.
  • otherwise dealing with any of the Finplify Affiliates/Entities/Subsidiaries/Associates.
  • while applying for career opportunities with Finplify.


We and our service providers or business partners may also collect your Personal Information from third parties or information made publicly available including but not limited to:

  • Financial history and other information for the purpose of verifying and authenticating an investment transaction request you place with us to prevent suspicious transactions, or to comply with court judgements and bankruptcies, from credit reference and fraud prevention agencies.
  • Your resume, your past employment and educational qualification for background checks and verifications, through online or offline databases that are otherwise legitimately obtained in case you apply for employment opportunities with Finplify.
  • Your demographic and photo information including but not limited to Aadhaar number, address, gender, and date of birth as a response received from UIDAI upon successful Aadhaar e-KYC.


Information Sharing and Disclosures

Your Personal Information is shared as allowed under applicable laws, after following due diligence and in line with the purposes set out in this Policy. We may share your Personal Information in the course of your transaction with different categories of recipients such as business partners, service providers, merchants, affiliates, associates, subsidiaries, legally recognized authorities, regulatory bodies, governmental authorities, financial institutions, internal teams such as marketing, security, investigation team, etc.

Personal Information will be shared, as applicable, on need-to-know basis, for the following purposes:

  • for enabling the provision of the products/services availed by you and facilitating the services between you and the service provider, as requested.
  • for the Aadhaar authentication process by submitting Aadhaar information to Central Identities Data Repository (CIDR) and National Securities Depository Limited (NSDL).
  • for complying with applicable laws as well as meeting the Know Your Customer (KYC) requirements as mandated by various regulatory bodies, whose regulated service/product you opt through our services/Platforms.
  • for completing a payment transaction initiated by you on a merchant site, where based on your instructions, the merchant requests to fetch your Personal Information from us.
  • for the purpose of processing your financial product subscription requests placed with us and ensuring that these requests reach the relevant financial institution whose service/product you have opted for.
  • if it is required by financial institutions to verify, mitigate, or prevent fraud or to manage risk or recover funds in accordance with applicable laws/regulations.
  • for services related to communication, marketing, data and information storage, transmission, security, analytics, fraud detection, risk assessment and research.
  • enforce our Terms or Privacy Policy; respond to claims that an advertisement, posting, or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public.
  • if required to do so by law or in good faith we believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process
  • if requested by government authorities for government initiatives and benefits.
  • for grievance redressal and resolution of disputes.
  • with the internal investigation department within Finplify or agencies appointed by Finplify for investigation purposes located within or outside the Indian jurisdiction.
  • should we (or our assets) plan to merge with, or be acquired by any business entity, or re-organization, amalgamation, restructuring of our business then with such other business entity.

While the information is shared with third parties as per purposes set out in this Policy, processing of your Personal Information is governed by their policies. Finplify ensures stricter or no less stringent privacy protection obligations are cast on these third-parties, wherever applicable and to the extent possible. However, Finplify may share Personal Information with third-parties such as legally recognized authorities, regulatory bodies, governmental authorities, and financial institutions as per purposes set out in this Policy or as per applicable laws. We do not accept any responsibility or liability for usage of your Personal Information by these third parties or their policies.

Securtiy Policy

We understand that as effective as our security measures are, no security system is impenetrable. Hence, as part of our reasonable security practices, we undergo strict internal and external reviews to ensure appropriate information security encryption or controls are placed for both data in motion and data at rest within our network and servers respectively. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited.

Further, you are responsible for maintaining the confidentiality and security of your login id and password. Please do not share your Finplify login, password, and OTP details with anybody. It shall be your responsibility to intimate us in case of any actual or suspected compromise to your Personal Information.

We have provided multiple levels of security to safeguard the Finplify Application by login/logout option and Finplify Application lock feature (“Enable Screen Lock”) that can be enabled by you. We have preventive controls implemented to ensure you use Finplify Application on your device and the same login credentials cannot be used on different device without any additional authentication/OTP.

Storage and Retention of Data

To the extent applicable, we store Personal Information within India and retain it in accordance with applicable laws and for a period no longer than it is required for the purpose for which it was collected. However, we may retain Personal Information related to you if we believe it may be necessary to prevent fraud or future abuse or if required by law such as in the event of the pendency of any legal/regulatory proceeding or receipt of any legal and/or regulatory direction to that effect or for other legitimate purposes.

Once the Personal Information has reached its retention period, it shall be deleted in compliance with applicable laws.

Third-Party Products, Services, or Websites

When you are availing products and services of service providers on Finplify Platform, Personal Information may be collected by respective service providers and such Personal Information shall be governed by their privacy policy. You may refer to their privacy policy and terms of service to understand how your Personal Information will be handled by such service providers.

Our services may include links to other websites or applications when you visit our Platform. 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 or on the m-site you are redirected to), use of any Personal Information that you provide on these websites or applications is governed by the privacy policy of the operator of the application/website, 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. We do not accept any responsibility or liability for usage of your Personal Information by these third parties or their policies.

User Consent

We process your Personal Information with consent. By using the Finplify Platform or services and/or by providing your Personal Information, you consent to the processing of your Personal Information by Finplify in accordance with this Privacy Policy. If you disclose to us any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

Opt out of Receiving Services

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 an account. If you want to remove your contact information from all our lists and newsletters or discontinue any our services, please click on the unsubscribe button on the emailers. From the application, you can choose to delete your account and all personally identifiable information will be deleted within 24 hours of the request.

In cases where you need any further information specific to the product/ services that you are availing, we request you to read through the Terms and Conditions specific to the product/service which is easily accessible through the Finplify Platform. For seeking any further information on the same, you can write to us at the details mentioned in the ‘Contact Us’ section of this Policy.

Changes to Policy

Since our business changes constantly, so will our policies. We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time without any prior written notice to you. We may, however, reasonably endeavour to notify you of the changes, it is your responsibility to review the Privacy Policy periodically for updates/changes. Your continued use of our services/Platform, following the posting of changes will mean that you accept and agree to the revisions. We will never make changes to policies in order to make it less protective of Personal Information already shared by you.