PRIVACY POLICY

Effective as of 15 June, 2021


1.     INTRODUCTION

1.1    Flat White Capital Private Limited, an Indian company incorporated as per the provisions of the Companies Act, 2013 having its registered office at A-74 Panchvati Apartments, Vikas Puri, New Delhi, (“Company”/ “We”/ “Our”/ “Us”) are committed to protecting your privacy and grant importance to the confidentiality of your data over internet. This privacy policy (“Privacy Policy”) shall apply to all persons using or accessing (“Users”, “You” or “Your”) any or all products, services, features or content, offered on the internet website www.indiagold.co (“Website”), the mobile application “indiagold” (“App”) and all domains and subdomains owned by indiagold.

1.2    This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents/ records in various statutes as amended by the Information Technology Act, 2000. This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between the User and Us.

2.     GENERAL

2.1    In this Privacy Policy, “Personal Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. (“Personal Information”). Personal Information does not include anonymized information that has been appropriately processed to make it non-identifiable in order to irreversibly prevent its identification. Further, Information Technology Act, 2000 and the rules made thereunder, defines “Sensitive Personal Information” of a person to mean Personal Information about that person relating to:

  1. passwords
  2. financial information such as bank accounts, credit and debit card details or other payment instrument details
  3. physical, physiological and mental health condition
  4. name, age, address, e-mail, phone number, date of birth, sexual orientation
  5. medical records and history
  6. biometric information
  7. information received by body corporate under lawful contract or otherwise
  8. visitor details as provided at the time of registration or thereafter
  9. Call log permission for authenticating mobile number used for logging in to the app

Provided, however, that such information will not be considered as sensitive if it is freely available and accessible in the public domain or is furnished under the Right to Information Act, 2005, any rules made there under or any other law for the time being in force.

“Personal Information” and “Sensitive Personal Information” shall be collectively referred to as “Personal Information”

2.2    The purpose of this Privacy Policy is to inform the User about the processing of his/her personal data collected when using the services available on the Website/App. We collect and utilize Your Personal Information only to enhance, maintain, protect, improve the services (including advertising services) and operation of the Website/App, allowing You to use all the listed features and allowing Us to respond to Your requests. The Personal Information is used strictly in line with Our business purposes in the right spirit and context and to provide You with useful features.

2.3    By providing us Your Personal Information or by downloading and using the App and/or Website site, You expressly give Us consent to collect, store, process, use & disclose Your Personal Information in accordance with this Privacy Policy. If You do not agree to the terms of the Privacy Policy, please do not use or access products, services, features, or content provided by the App and/or Website.

2.4    We respect the privacy of Our Users and are committed to protect it in all respects. The information about the User is collected by Us as (i) information supplied by Users; (ii) information automatically tracked during User’s navigation on the Website/App; and/ or (iii) communicated directly to Us via e-mail or telephone or another channel.

2.5     The User acknowledges that this Privacy Policy, together with terms and conditions, forms Our agreement with the User in relation to his/her use of the Website/App. The Company presumes adequate and lawful parental consent in case the Personal Information is shared by a User under the age of 18 (eighteen) years.

2.6    For any service that User may use, We only collect the data that is strictly necessary (i) for the delivery of the services, (ii) for the performance of a contract for which User is a party, (iii) for which User has given consent for such processing of data, or (iv) for compliance with a legal obligation to which We are subject.

3.     INFORMATION COLLECTED

3.1    If You visit Our Website/App or service just to browse, read pages or download information, We automatically track and collect the following categories of information (including but not limited to):

  1. IP addresses
  2. Domain Servers
  3. Other information with respect to Users device, operating system, interaction of User device with the Website/App and application.
(hereinafter referred to as the "Web Browser Information")

This information cannot and does not identify You personally.

3.2    In order to provide services through the Website/App, We may require the User to provide Us with the following categories of information:

  1. Contact data (such as name, address, email address, phone number and date of birth); and
  2. About Your location such as time zone, postal address and location details) to provide You better & prompt customer service;
  3. If the User communicates with Us by, for example, e-mail or letter, any information provided in such communication may be collected by Us;
  4. Your photo if you choose to add one to Your profile on Website/App;
  5. Information from Your smartphone as per app store policies. You authorize Us to have access to this information and You agree that We may collect and use this information in accordance with this Privacy Policy;
  6. Access the file storage for saving the receipt of the purchases;
  7. Financial data (such as account details, e-wallet details, bank account or credit or debit card details or other payment instrument details etc.) [or credit score] that User may have provided Us. We work with multiple payment processors who store these details in encrypted format. All Our payment processors are Payment Card Industry Data Security Standard (PCI DSS) compliant;
  8. Personal information stored with third parties that You choose to provide to Us, such as Your social media account information and Your social media contacts. By linking Your third-party accounts or using third party sign-in services, You authorize Us to have access to this information and You agree that We may collect and use this information only in accordance with this Privacy Policy.

3.3    Biometrics Information- Your biometric identifiers and biometric information such as fingerprints, faceprints and voiceprints may be collected in order to provide you the locker services. This data will be stored in the locker and we do not access such information in our servers. You acknowledge and consent that such biometric information may be subject to the terms and conditions including privacy policy of the vault provider.

3.4    Copy of Aadhaar information You may provide as proof of identity or address for KYC processes.

All such information is stored or used for processing orders and under no circumstance are any of these details made available in the public domain. However, We may use this information to share with You additional and/ or upcoming information regarding the services of Website/App in accordance with this Privacy Policy.

4.     YOUR RIGHTS

You have the right in certain circumstances to:
  1. withdraw your consent where you have given your consent to us to use your Personal Information for certain purposes. You have the right to withdraw this consent at any time by contacting us in writing using the contact details set out in the “Contact Us” section. This will not affect the lawfulness of any use of your information that we make before you withdraw your consent. Further, We will have the option to stop providing you services for which the said information was sought.
  2. access and review the Personal Information You have provided to Us. If the review reveals that Personal Information has been recorded incorrectly or is incomplete You may contact us via e-mail at the details as set out in the “Contact Us” section below to correct any such inaccuracies;
  3. restrict the processing of your Personal Information if one of the following applies to you:
    1. you contest the accuracy of the information that we hold about you, while we verify its accuracy.
    2. we have used your information unlawfully, but you request us to restrict its use instead of erasing it.
    3. we no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim.
    4. you have objected to us using your information, while we check whether our legitimate grounds override your right to object.
  4. object to the processing of your Personal Information on the basis of our legitimate interests.
  5. require us to erase your Personal Information without undue delay if one of the following applies, unless it is necessary to use your Personal Information to comply with a legal obligation or to establish, exercise or defend a legal claim:
    1. the information is no longer necessary for the purposes for which we collected it.
    2. you object to us using your information: for the purposes of understanding the visitors to the website and there are no overriding legitimate grounds for the processing.
    3. you unsubscribe from our marketing communications.
    4. we have used your information unlawfully.
    5. the information must be erased for compliance with a legal obligation to which we are subject.
  6. port your Personal Information under certain circumstances.

5.     RETENTION OF PERSONAL INFORMATION

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for the purpose for which we collected such data or as legally mandated. We will retain Personal Information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. We may retain your Personal Information to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, enforce our general terms of use, and take other actions as permitted by law and as required to provide the Service. Once the purpose is satisfied or the legally mandated period has expired, we will securely delete your Personal Information.

6.     COOKIES

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. To improve the responsiveness for our users, we may use “cookies”, or similar electronic tools to collect information to assign each User a unique, random number as a user Identification (user ID) to understand the user’s individual interests using the identified computer. Unless You voluntarily identify yourself (through registration, for example), We will have no way of knowing who You are, even if We assign a cookie to Your computer. The only Personal Information a cookie can contain is information You supply. A cookie cannot read data off your hard drive. Cookies cannot be used to run programs or deliver viruses to Your computer. We receive and store certain types of information whenever you interact with us via Website/App or service though your computer/laptop/netbook or mobile/tablet/pad/handheld device etc.

7.     DISCLOSURE AND INFORMATION SHARING

  1. We may share the Sensitive Personal Information to any third party/service provider in the following limited circumstances and You here by provide us with your consent for the same:
    • When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms and Conditions; for complying with the applicable laws and regulations.
    • Within its group companies and officers and employees of such group companies for the purpose of processing Personal Information on its behalf. We also ensure that these recipients of such information agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
  2. We shall take all reasonable steps to ensure that the confidentiality of Your information is maintained by imposing strict confidentiality standards on all the third parties with whom We part this information. In all circumstances, We shall ensure that Your Personal Information is protected by strict confidentiality agreement. We shall not allow any third parties to retain Your Personal Information longer than what is warranted by the nature of services rendered.
  3. We do not disclose Your Personal Information to any advertisers or any third party for their marketing and advertising purposes without Your explicit consent.
  4. We use Users Personal Information to display relevant promotions and marketing offers, based on his/her preferences. To the extent we use Your Personal Information to market to You, We will provide You the ability/right to opt-out of such uses at any time, directly by clicking on the unsubscribe link available on each email received, by modifying his account settings, or by contacting Us at the following email address: help@indiagold.com

8.     LINKS TO THIRD PARTY SITES

  1. Our Website/App may contain links to third party websites or applications. The User agrees and understands that privacy policies of these websites are not under Our control and the User understands that once he/she leaves Our servers, use of any information provided by the User or Your Personal Information shall be governed by the privacy policy of the operator of the site used by him/her.
  2. When the User accesses another website through a link or a URL available on the Website/App, this Privacy Policy does not apply anymore. We shall in no way be responsible in any way for Your use of such sites.
  3. We are not responsible for the content or the privacy polices of third party websites
  4. List of third parties being used: Bugsnag, Haptik, Strapi, RazorPay, ValueFirst, FreshDesk, Ameyo, Interakt, Amplitude, Experian, IP Data, Nucleus, Onetap, Sinch

9.     SECURITY

  1. The security of Users Personal Information is important to Us. We follow generally accepted industry standards to protect the Personal Information submitted to Us, both during transmission and once We receive it. All information gathered on Our Website/App is securely stored within our controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited.
  2. This Personal Information is immediately deleted once User deletes the App or deletes his account exclusively made on the Website, except to the extent it is necessary to store the same under applicable laws. Further, We have implemented commercially reasonable physical, managerial, operational and technical security measures to protect the loss, misuse and alteration and to preserve the security of the Personally Information in Our care.
  3. Although We make best possible efforts to store Personal Information in a secure operating environment that is not open to the public, User must understand that there is no such thing as complete security, and We do not guarantee that there will be no unintended disclosures of Personal Information. If We become aware that Users Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, We will use reasonable efforts to notify such User of the nature and extent of such disclosure as soon as reasonably possible and as permitted by law.

10.     FEEDBACK AND GRIEVANCES

We reserve the right to modify at any time this Policy Privacy and to inform User by any mean.

11.     REVIEWING AND UPDATING PERSONAL INFORMATION

In accordance with the legislations in force, User has the right to access, to rectify and to object data concerning himself/herself. User can access and change the Personal Information and preferences provided when account is created through the account page or by contacting Us. We shall ensure that any Personal Information found to be inaccurate or deficient shall be corrected or amended as feasible.

12.     CONTACT US

If you have any questions, comments or concerns about Our privacy practices or would like to provide a feedback on the services offered on Website/App, please contact Our grievance officer, Arihant Jain by e-mail at help@indiagold.co. Our support centres are operative throughout the week between 10am and 6pm (subject to holidays).