PERSONAL INFORMATION COLLECTION

We collect and process your personal information with your consent. We collect the Personal Information that is relevant and essential for providing the services requested by you and for registering you and your device on Finobuddy Digital Platform. Personal and Sensitive Personal Information collected includes:

1. Personal information including name, age, sex, date of birth, marital status, nationality.
2. Occupation, photo, e-mail ID, contact information. We may also ask you to share your location.
3. Transaction information such as date of the transaction, transaction amount, transaction history and related details if you have availed or purchased any products or services from Finobuddy Digital Platform.
4. KYC related information such as PAN, income details, other online/offline verification documents as mandated by regulatory authorities.
5. Aadhar information including Aadhar number or Virtual ID for the purposes of e-KYC authentication with the Unique Identification Authority of India (UIDAI).
6. Income range, investment goals, investment details and transactions, expense range.
7. Your aptitude and interests when you are opting for Career Guide services available on the Finobuddy Digital Platform. We may ask you to share your investment patterns, loans, and saving habits to help us understand your risk profile and provide you strategies and practices to maximize your savings.
8. Religion if you are opting for WILL drafting services available on the Finobuddy Digital Platform.
9. Your short messaging service (SMS(es)) that are stored on your device for the purpose of registering you and your device for payments or investment services, OTPs for log in and payments, analysing your spending habits under various expense heads for recommending a personalised financial solution which is aligned with your risk profile, and any other legitimate uses with your explicit consent.

We collect the personal information that is relevant and essential for providing the services requested by you. We collect the personal information in the following circumstances:

• When you interact with the Finobuddy Digital Platform and you voluntarily provide us the personal information requested by us.
• When you avail, apply, or purchase any products or services available/listed on the Finobuddy Digital Platform.
• When you transact through your Finobuddy Digital Platform account.

PURPOSE AND USE OF INFORMATION

Finobuddy Digital Platform may process your personal information for the following purposes:

• For verification of your identity and creation of your account on Finobuddy Digital Platform.
• Provide you access to the products and services available on the Finobuddy Digital Platform and to facilitate transaction for various products and services available on the platform.
• To conduct the KYC compliance process as mandated under the laws for investments in various financial products. KYC is a mandatory process designed to verify the identity of investors to prevent fraud, money laundering, and other illegal activities. Personal Information including your sensitive personal information is required for your Know Your Customer (KYC) process for several important reasons including Identity Verification, Prevention of Fraud, Compliance with Regulations.
• To validate, process and/or share your KYC information with various Asset management companies or with any other services providers listed on our Finobuddy Digital Platform.
• After obtaining your explicit consent, we access your short messaging service (SMS(es)) that are stored on your device for the purpose of registering you and your device for payments or investment services, OTPs for log in and payments, analysing your spending habits under various expense heads (expense analyser)  for recommending a personalised financial solution which is aligned with your risk profile, and any other legitimate uses. Giving consent to access your SMS text messages is entirely optional.
• To facilitate the offer of services by Career Guide and Health Assure from our Finobuddy Digital Platform.
• We need to know your religion for providing WILL drafting services. In India, different religions are governed by different personal laws when it comes to inheritance and succession. Knowing the religion of the user helps determine which set of laws will apply while drafting the WILL.
• To authenticate a transaction request and to validate a standing instruction for a systematic investment plan
• We may also ask you to share your location. Location data can help identify unusual account activity. We ask you to share your location typically to enhance the functionality of the service or to provide a better user experience.
• To resolve disputes, troubleshoot problems, technical support, and fixing bugs.
• To identify security attacks, and taking action on suspected frauds or money laundering activities
• To assess your risk profile and to provide you a personalised financial solution we need to know your Income range, investment goals, investment details and transactions, expense range. The said information is collected with your consent.
• To meet regulatory obligations.

SHARING OF INFORMATION

We disclose your information including personal information and sensitive personal information to the following categories of recipients:

1. To our partner entities such as banks, financial institutions and other business entities listed on our Platform to deliver products and/or services to you. By using this Platform, you consent to any such disclosure of your information with such Partner Entities. Please note that such partner entities use your personal information including your sensitive personal data or information for the purpose of providing their own products or services. Their use of such personal information including sensitive personal information is also subject to their own privacy policies.
2. To third party service providers who provide data processing services to us and support us in providing our services. We provide your personal information including sensitive personal information to such service providers for a specific purpose pursuant to a written contract. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes.
3. To a potential buyer in connection with any proposed purchase, merger or acquisition of any part of our business provided that we inform the potential buyer that it must use your personal information including sensitive personal information only for the purposes disclosed in the privacy notice.
4. We may also share your personal information including your sensitive personal data with other third parties where we need to comply with applicable law or respond to valid legal process.

SECURITY

We will use technical, organisational and administrative measures to safeguard your personal information including your sensitive personal information. We store such information on secure servers. In addition, we limit access to your personal information and sensitive personal information to those employees, agents, partner entities, contractors and other third parties who have a business need to know. They will only process your personal data as may be required to deliver products and/or services to you and they are subject to a duty of confidentiality. Please note that you are responsible for maintaining the security of your credentials used to access any service on Finobuddy Digital Platform and you must report suspected unauthorized activity by emailing us at mylead@myleadfintech.com.  Further,

1. To protect personal information and sensitive personal data or information from unauthorized access and use, Finobuddy Digital Platform uses security measures that comply with applicable laws.
2. We have implemented physical, electronic, and procedural safeguards in accordance with applicable laws, industry standards, and best practices.
3. The database is stored on servers secured behind a firewall; access to the servers is password protected and is strictly limited.

THIRD PARTY PRODUCTS, SERVICES, OR WEBSITES

Finobuddy Digital Platform may provide links to websites and applications of various service providers, whose privacy policy differ from those of Finobuddy Digital Platform. Personal Information collected by such service providers will be governed by their privacy policy. It is hereby clarified that for availing any products and services of service providers on Finobuddy Digital Platform, Personal Information may be collected by respective service providers. Personal Information so collected by them shall be governed by their Privacy Policy in addition to our Privacy Policy. You may refer to their Privacy Policy prior to disclosing any information.

COOKIES

“Cookies” are small files placed on your device that assist us in providing our services. Cookies do not contain any of your Personal information including your sensitive personal data or information. We offer certain features that are only available through the use of a cookie or similar technologies. We also use cookies to allow you to enter your password less frequently during a session. Most cookies are automatically deleted from your device hard drive/storage at the end of a session. You are always free to decline/delete our cookies or similar technologies if your browser/device permits, although in that case you may not be able to use certain features on the Platform.

CONSENT

We process your Personal Information and sensitive personal data or information with consent. By using our Finobuddy Digital Platform or by providing your Personal Information and sensitive personal data or information,  you consent to the processing of your personal information and sensitive personal data or information in accordance with their 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 to permit us to use the data in accordance with this Privacy Policy.

PERSONAL INFORMATION ACCESS, RECTIFICATION, REVOCATION OF CONSENT

You may access, review, correct, and update your Personal Information and sensitive personal data or information by writing to us at the contact information provided below. In addition, you may at any time revoke consent given to us to store your Personal Information/Sensitive Personal Information. Upon such revocation, you may lose access to services that were availed on the basis of the consent provided. To raise any of the above requests, you may write to us using the contact information provided below. We will verify such request before acting upon your request. Please note, however, that withdrawal of consent will not be retroactive and will be in accordance with the terms of this Privacy Policy, related terms of use and applicable laws. Further, withdrawing your consent will not affect the lawfulness of any processing of your personal information including sensitive personal data done prior to your withdrawal.

OPT OUT

After setting up an account on Finobuddy Digital Platform, we provide all users with the opportunity to opt out of any our services. If you want to remove your contact information or discontinue our services please write to us at the contact information provided below.

DATA RETENTION

We shall retain information that we collect or process on your behalf for as long as may be needed to provide the Services. We store your personal information within India and retain it in accordance with the applicable laws as long as we have ongoing legitimate business needs to do so. We will retain and use such information as necessary to comply with our legal obligations and/or for the period required by law in the applicable jurisdicions.

SEVERABILITY

If any court or competent authority finds that any provision (or part of provision) of this Privacy Notice to be invalid, illegal or unenforceable that provision or part of provision will to the extent required, be deemed to be deleted, and the validity and enforceability of this Privacy Policy will not be affected.

MINOR

We do not offer any products or services for use by minors. Our Finobuddy Digital Platform is not intended for individuals under the age of 18. Finobuddy Digital Platform is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are under the age of 18 years, then you must use the Finobuddy Digital Platform under the supervision of your parent or legal guardian.

CHANGES

We reserve the right make changes to this Privacy Policy from time to time to incorporate necessary changes in technology, applicable law or other factors. The Privacy Policy as and when modified, shall be updated on this platform. It is your responsibility to review this privacy policy periodically to remain informed about how your personal information is used. Your continued use of our services/Finobuddy Digital Platform, following the posting of changes will mean that you accept and agree to the revisions.

CONTACT INFORMATION

The name and contact details of the Grievance Officer is provided hereunder to address all your queries, concerns, complaints, and grievances in accordance with the Information Technology Act, 2000, and Rules made thereunder. We are committed to answer your questions within the reasonable time limit. Any delay in the resolution time shall be proactively communicated to you.

1. Grievance Officer: Soumyadip Dutta
2. Email address: soumyadip.d@myleadfintech.com
3. Contact Number: +91 7411927639
4. Address: 206, The Summit Business Park, Off Andheri-Kurla road, Andheri East, Mumbai-400093