Privacy Policy
RADICAL PRIVACY POLICY
Effective Date: May 30, 2022
GENERAL
We are committed to keep your data secure, your private information private, and being transparent about our practices. We adhere to the best practices to secure information collected from you.
Radical Advisors India Private Limited, a private limited company, incorporated under the provisions of the Companies Act, 2013, having its registered office at 520, Somdutt Chamber-II, 9 Bhikaji Cama Place, New Delhi- 110066 and its Affiliates/ Subsidiaries/ Associates including but not limited to Radical Advisors India Private Limited, (hereinafter referred as “We”, “Us”, “Our”, or “Company” or “Radical”) owns, operates and manages a website having domain name https://www.finezzy.com/ and related software application for use on wireless computing devices such as smartphones and tablets and also for use on desktop or laptop computers under the name and style of “FinEzzy” (collectively hereinafter referred to as “Platform” or “Application”).
The Platform facilitates and enables the User in availing certain online products and services from the Platform, including, inter alia, investment and wealth management services to the Users (“Services”), in accordance with the terms and conditions of use/Service of the Platform, as available athttps://www.finezzy.com/t-cs (“Terms of Use”).
For the purposes of this privacy policy (hereinafter referred to as “Privacy Policy” or “Policy”), wherever the context so requires, references to the terms “User(s)”, “You” or “Your”, shall mean and include the user, registered on the Platform, who uses or access the Platform or avails the Service(s) (as defined below) of the Platform in accordance with the Terms of Use.
This Privacy Policy is published in compliance with the Information Technology Act, 2000, and applicable amendments, rules, regulations and guidelines enacted thereunder from time to time (“IT Act”) with specific mention of regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive personal information) Rules, 2011, and any other national and state laws which relate the processing of data. This Privacy Policy is an electronic record in terms of the IT Act and this electronic record is generated by a computer system and does not require any physical or digital signatures. Any new features and/or services that are added to Our current service at any point in the future shall also be subject to the terms set out in this Policy along with any other future relevant legislations to be incorporated as per the laws of the land. This Privacy Policy shall apply to any person who visits, browses, uses or accesses the Platform or use any Services on the Platform.
This Privacy Policy, inter alia, states: (i) the type of information collected from the Users, including personal information and sensitive personal data or information (as defined below), relating to an individual; (ii) the purpose, means and modes of collection, usage, processing, retention and destruction of such information; (iii) how and to whom We will disclose such information; and (iv) how We will protect the Users’ personal information when they access the Platform.
FinEzzy does not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to FinEzzy. If FinEzzy learns that we have collected personal information from a person under age 18, we will delete that information as quickly as possible. If you believe that a person under 18 may have provided us with personal information, please contact us at info@radicaladvisors.com.
This Privacy Policy is published to inform and describe Our Users of Our policies and procedures regarding collection, storage, and processing and sharing of information that We receive from our Users on the Platform or those which are stored or accessed by Us at the time of availing/ registering for the Services or making transactions on the Platform. We have developed this Policy to familiarize You with Our practices and demonstrate Our commitment to the protection of Your privacy and Your personal information. With regard to this Privacy Policy, the terms “using”, and “processing” information include, without limitation; the use of cookies; and the collection, storage, transfer, evaluation, deletion, disclosure, management, handling, modifying and use of information.
- This Privacy Policy is applicable to all Users of this Platform. By using the Services, registering with Us or by otherwise giving Us Your information, You shall be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by the terms hereof as laid down.
- We respect Your need to understand how and why information is being collected, used, disclosed, transferred and stored. This Privacy Policy sets out the way in which We process Your information when You visit the Platform or use the Services in accordance with applicable relevant data protection laws. By accessing Our Platform or availing the Services, You agree to be bound by the terms of this Policy.
- It is important that You read this Policy together with any or all other policies We may provide on specific occasions when We are collecting or processing your personal information, so that You are fully aware of how and why We are using your personal information.
- This Privacy Policy applies only to information that You provide Us via the Platform. We reserve the right to update this Privacy Policy from time to time to reflect any changes to Our Services. We will do this by amending the Privacy Policy on the Platform and intimate the changes which will take effect automatically as soon as they are posted on the Platform. In addition, We shall notify all Our Users by email or any specified mode of communication with respect to the changes that are made to the Policy.
- The information contained on this Platform and the information collected by using/ login and /or accessing this Platform are stored at a secured server. It is stated by the server service provider that they have all the best security practices required for the server. The Platform is owned by Us and is located in India. Hence, We are bound by duty to abide by the laws, including but not limited to, regulations, rules, circulars and notifications governing privacy in India.
- This Privacy Policy does not apply to any third-party website(s) and mobile app(s). You are requested to take note that information and privacy practices of Our business partners, advertisers, sponsors or other sites to which We provide hyperlink(s), may be different from this Policy, Hence, it is recommended that You review the Privacy Policy of any such third parties before You interact with such interfaces. Under such circumstances we kindly recommend you to read the policies on the applicable / relevant websites or sources.
- You hereby consent to Us collecting, using and sharing and disclosing Your information as described in this Privacy Policy. If You do not agree with this Privacy Policy at any time, time, please do not use any of the services, use or access the Platform or give Us any of Your information.
In order to enable a User to have access to the features, benefits or use of the Services on Our Platform, the User may require to provide certain information on the Platform which may constitute ‘personal information’ or ‘sensitive personal data or information’ of a person which shall be governed under regulation 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive personal information) Rules, 2011, along with other relevant data privacy laws of the land and Prevention of Money Laundering Act (PMLA) 2002.
We may collect the following categories of personal information or sensitive personal data or information from the User but not limited to:
ON BOARDING / REGISTRATION OF SERVICES:
When You create a new account to use the Services we request for the following information:
- Name, DOB, Gender, Nationality, Father’s name, Mother’s name, Marital status, photo;
- Address, ZIP/postal code, location, phone number, e-mail id, your contacts and nominee details;
- Bank account number, your name on bank passbook and IFSC code of the bank;
- PAN card number, Aadhar card number(redacted), KYC related information either through videos or other online/ offline verification documents as mandated by relevant regulatory authorities, for the services you shall be utilizing (purpose of investments & transactions) and your business-related information.
- Employment related details (e.g. occupation, income, employer details, designation) as part of our record retention for Central KYC Records Registry (CKYCR) purposes under Prevention of Money Laundering (Maintenance of Records) Rules, 2005
- Information in relation to Your device by way of using our app like, communication information including contacts and call logs, device information (including storage, model, mobile network), browser plug-ins, and cookies or similar technologies that may identify your browser Application and plug-ins, notifications etc.
- To comply with regulatory requirements, based on Your explicit consent we fetch Your KYC (Know Your Customer) details from regulated Central KYC Registry
- Collect credit related information from third party service provider that are expressly authorised by You to distribute such information (for example, Experian or CRIF High Mark which is a credit information company registered under the Credit Information Companies (Regulation) Act, 2005).
- Giving an access to Your email is sought to provide a holistic view of your credit card account details such as total amount due, minimum amount due and due date statements from the applicable services, any other financial & transactional details, curated rewards and offers etc.
- We shall securely store account details for each of Your credit card accounts, including your sign-in username and authorisation tokens for tracked accounts. This information will be used to enable Us to automatically access Your applicable credit card statements to analyze, extract, and store information securely from such accounts for use in the Application.
- After obtaining such explicit consent from you, FinEzzy’s Android App may automatically read your SMS text messages pertaining to yours expenses and/or saving account balance data information arising out of transactions made from cards, banks, wallets through text messages (SMS) received by you from providers of services and/or banks (including but not limited to retail outlets, financial institutions, and utility companies) on your Android mobile device.
- This will enable us to organise your expenses and saving account balances across your transactions and banks in one view and also provide analytics on the same to you. This will also help you to get an accurate picture of your overall wealth and networth on your application dashboard.
- No personal SMSes or OTPs are accessed by FinEzzy.
- You can choose to opt-out of the expense and saving account balance analytics services at any time by writing to info@radicaladvisors.com. Alternatively, you can also opt-out of the expense and saving account balance analytics by visiting FinEzzy’s Android App permission settings.
- Enter the information manually: You provide investment details like scheme name, investment type, investment date and investment value by manually entering the data whenever necessary / applicable
- The User may also choose to provide explicit consent to connect/integrate the User’s Gmail account(s) with his/her account on the Platform. You will be expressly asked in each case particularly, whether You want to connect Your email address with Your account on the Platform. You can also choose to enable Our access to one or more of Your email accounts by connecting such account(s) with Your account on the Platform. The following are the information collected from Your consented email accounts:
- The attachments from the senders who have the details of your investments such as Folio numbers, Transaction Dates, Dividends, Subscription and Redemption Amounts. FinEzzy organizes this information in your account to provide deep analytics and other services.
- We access your Gmail account and seek your explicit consent in auto tracking your investments. You can choose to provide explicit consent to connect your Gmail account with FinEzzy account (using Google’s OAuth authentication method), so that the application / website can “read only” the attachment from a small white listed set of senders specifically comprising under the said terms which can be read https://www.finezzy.com/t-cs.
- The benefit of opting to connect Your Gmail account is that your investment information gets updated automatically every month. Given the updated information, the application can hence give you deep and accurate analytics on your net worth.
- You can choose to de-link your Gmail account with the application at any time and/ or you can delete your information by writing to info@radicaladvisors.com.
- Once connected, the Platform will securely access and analyse the contents of emails consisting of ‘read-only’ including but not limited to the attachments from selected list of senders, for the purpose of managing and tracking the User’s investment and financial details and history, such as particulars pertaining to investments and deposits made by the User in relation to fixed deposits, mutual fund, employees provident fund etc., including, the investments made through the account on the Platform and consolidate them at one place.
- Please note that such data obtained by this integration will be used by the Company solely for providing the Services, updating the User’s investment information on a monthly/ quarterly / annual basis, providing accurate analytics on the User’s investments and further improving the User experience pertaining to the features of the Platform. We shall not use or transfer any data or information received from the integration of the email addresses with the account on the Platform to third parties for any purpose other than as explicitly authorised by the User.
- We encourage the User to review the information prior to giving consent for integration of the email address with the account on the Platform. The User may at any time opt to de-link the email address connected with the account opened on the Platform and/or delete the information by writing to info@radicaladvisors.com.
PROCESSING OF PERSONAL INFORMATION
- Services opted in Platform (investments, deposits, transactions etc) to facilitate Your requests with respect to Our varied range of financial products and services offered by Us. For example, personal information is processed in order to organize and aggregate the User’s financial information in one place on the Platform, facilitate the Platform to provide the User analytics on their investments, liabilities & expenses, help the User to assess their risk profile from time to time, create the User’s investment plans and make decisions on investments.
- Value Added services to provide information to our Affiliate companies and its authorised agents and other third-party services providers so far as required for providing information about products/services of our Affiliate companies and / or to offer similar services and to provide you with various value-added services and information including for authentication purposes to enable linking of Your products held with Us.
- KYC compliance to conduct the KYC compliance process as a mandatory prerequisite as per the requirements of various regulatory bodies, to validate, process and/or share Your KYC details, nominee details with other intermediaries, Regulated Entities or financial institutions or with any other service providers as may be required;
- Sharing /Communication by sharing the information, You are allowed to contact either through Us or our thirdparty service providers through any channel of communication including but not limited to email, telephone, sms, etc.
- Alerts/ notices to intimate and deliver You any administrative notices, alerts, advice and communications relevant to Your use of the Service; to send You important notices and communications regarding Our services availed or changes to the terms and conditions and/or policies, to administer Our business and Platform;
- Customisation of platform/ offers to customize the content of Our Platform, request You for reviews of the Services; send You verification message(s) or email(s) validate/authenticate Your account and to prevent any misuse or abuse, to contact You on Your birthday and/or anniversary to inform You of any special offers if any available;
- Compliance with applicable laws to deal with enquiries and complaints raised by You and to troubleshoot problems, ensure compliance with all applicable laws and to ensure safety of the Platform and all Users, to prevent fraud, errors and/or any illegal activity on the Platform, for conducting audits and for record keeping purposes.
- Some sections on the Platform are freely accessible by all Users and visitors and require no prior registration. Further, certain sections on the Platform are accessible by Users only after entering their details, username and password. We request You to use a safe and secure server to access the Platform to ensure the safety of Your username, password and other information.
- We do not guarantee the security and/or privacy of any information, which may be available to all Users and visitors of the Platform publicly. Further, the Platform may contain links to other websites. Please note that We do not endorse any links or websites and are not responsible for the privacy practices of such thirdparty websites.
- We automatically receive the URL of the site from which anyone visits. We also receive the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide Web), User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of User’s ISP. This information is used to analyse overall trends to help Us improve Our Services. The linkage between User’s IP address and User’s personally identifiable information is not shared with or disclosed to third parties. Notwithstanding the above, We may share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow Our business.
- Please note that We maintain a strict no-spam policy and do not rent, sell, disclose or share personal information belonging to You with other people or non-affiliated companies without Your consent, except to provide you the Services which You have requested for or otherwise as specifically provided for in this Policy
You agree that in addition to as may be provided in this Policy, We may also disclose Your personal information under the following circumstances:
You agree that in addition to as may be provided in this Policy, We may also disclose Your personal information under the following circumstances:
Third party service professionals and/or providers: We engage, retain or might, as per requirement and business needs of the Company, employ, engage, contract with third party service professionals/providers to work on behalf of or with Us, under agreements containing confidentiality obligations and in accordance with law, in relation to the services provided by Us on the Platform. These third-party service providers may use Your personal information in assisting Us to communicate with You about Our offers, feedback of Services, assisting in payment facilities, providing customer support, assisting in advertising on the Platform etc. We may employ third party companies and/or individuals to help improve or facilitate our service, to provide the Service on our behalf, to perform platform-related services, including but not limited to: payment processing, maintenance services, fraud detection services, database management, web analytics, monitoring, delivery/logistics and evaluation services. In this event, your information may be shared with such third-party companies and/or individuals;
Compliance with laws and protection of Users, We may release your personal information when the same is required in order to comply with the law, in response to court orders, court summons, judgments, decrees, injunctions, arbitral awards, administrative orders, governmental investigation or orders of any government authority or any other legal process, to establish/exercise Our legal rights or defend against legal claims or in the event We reasonably believe that doing so is legally required or is in your interest to protect Your property or other legal rights or property or rights of others. We may also share your personal information in order to enforce and fully comply with Our terms of service and other Company policies;
Business transfer and mergers: We may transfer Your personal information if the Company, is acquired by or merged with another Company, to the extent permitted by applicable law and/or required under the scheme/arrangement of merger, etc. In such an event We will notify You before Your personal information is transferred/shared with the other entity and hence becomes subject to a different Privacy Policy;
Contracting parties: We transfer/share Your information with Our service professionals, group companies or business partners to facilitate the availing/provision of Services by You.With Your consent in addition to the aforementioned circumstances, We may share Your personal information with third parties with Your prior consent and/or at Your request if necessary at future course of time.
COLLECTION AND USE OF NON-PERSONAL DATA
Non-personal data is data that can never be used to identify an individual. We may collect information regarding customer activities on Our Platform. This aggregated information shall be used by Us in research, analysis, to improve and monitor Our services and for various promotional schemes and offers. Such non personal data may be shared in aggregated, non-personal form with third party to enhance customer experience, offerings or services. The Platform uses cookies, and while using the Platform You will be prompted to accept all cookies. We may place text files in the browser files of Your computer system.
COOKIES POLICY
A cookie itself does not contain personal information and it will only enable Us to relate Your use of the Platform and Your behaviour on the Platform to information that You have specifically and knowingly provided. The only personal information that a cookie can contain is the information You supply to the cookie. A cookie can’t read data off Your hard disk or read cookie files created by other websites.
We may place both permanent and temporary cookies. A permanent cookie will remain on Your web browser until its expiry date, unless deleted prior to such expiry date. However, most cookies are “session cookies” meaning that they automatically get deleted from your computer system at the end of the session. You can refuse cookies by turning them off in Your browser or alternatively You can also set your browser to warn You before accepting any cookies. Therefore, You are always free to decline Our cookies if Your browser permits, however We use certain cookies to authenticate Users on each page after the User logs on to the Platform or accesses any Services. If you, as a casual visitor, have inadvertently browsed any other page of this Platform prior to reading this Privacy Policy, and you do not agree with the manner in which such information is obtained, collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by Us. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as We cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Platform. Please note that You are not a casual visitor if you have willingly submitted any personal information or information to Us through any means, including email, post or through the registration process on the Platform. All such visitors will be deemed to be, and will be treated as Users for the purposes of this Privacy Policy, and in which case, this Privacy Policy applies in its entirety to such persons.
The data that cookies collect will be used to process and/or analyse information by third parties to help improve or facilitate Our services, to provide Service on Our behalf, to Platform-related services, including but not limited to; maintenance services; fraud detection services; database management; web analytics; monitoring; and evaluation services. If you have any questions about Our cookie usage, please contact Us at the contact details/information mentioned below.
YOUR RIGHTS AND HOW TO EXERCISE THEM
We respect the exercise of the rights You have in relation to the personal data and information We process or use. You can request access to or a copy of your personal and information collected and processed by Us. You may also request the rectification and removal of personal data and information or the restriction of the processing of Your personal data and information. Users have the right to unilaterally change their e-mail and contact preferences at any time by logging into their “Account” on the Platform and changing the account settings. You also have the right to data portability. If You have an objection to use of Your data under this Policy, please write to Our privacy team at contact information given below. To prevent misuse, We will ask You to identify yourself.
DISCLAIMER OF INFORMATION
We respect the exercise of the rights You have in relation to the personal data and information We process or use. You can request access to or a copy of your personal and information collected and processed by Us. You may also request the rectification and removal of personal data and information or the restriction of the processing of Your personal data and information. Users have the right to unilaterally change their e-mail and contact preferences at any time by logging into their “Account” on the Platform and changing the account settings. You also have the right to data portability. If You have an objection to use of Your data under this Policy, please write to Our privacy team at contact information given below. To prevent misuse, We will ask You to identify yourself.
You are responsible for maintaining the accuracy, truthfulness, correctness and completeness of the information You submit or provide to Us, on the Platform; and shall hold harmless and indemnify Us from and against all claims arising out of or in relation to the wrongful information posted, provided by You to Us, on the Platform. If Your personal information changes, You may correct, delete inaccuracies, or amend information by making the change on Our member information page or by contacting Us on the contact information given below. There may be circumstances where We will not correct, delete or update Your personal data information, including; (i) where the personal data and information is opinion data that is kept solely for evaluative purpose; and (ii) the personal data information is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed. If you wish to cancel your account or request that We no longer use your information to provide you Services, you may contact us on the contact information given below.
- The Platform uses a reliable SSL certificate to ensure Your personal data and information is not misused in any manner whatsoever. We use SSL encryption when transmitting certain kinds of information, such as financial services information or payment information.
- Our employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every User’s personal information or sensitive personal data and information.
- We have put in place procedures and technologies as per good industry practices and in accordance with the applicable laws, to maintain security of all personal data and information from the point of collection to the point of destruction. Any third-party data processor to which We transfer personal data and information shall have to agree to comply with those procedures and policies or put in place adequate measures on their own.
- No administrator of the Platform will have knowledge of Your OTP. It is important for You to protect against any unauthorized access to Your OTP, Your contact details and Your mobile phone. Ensure You log off from the Platform when finished. We do not undertake any liability for any unauthorized use of Your account.
- If You suspect any unauthorized use of Your account, you must immediately notify Us by sending an email to info@radicaladvisors.com. You shall be liable to indemnify Us due to any loss suffered by Us due to such unauthorized use of Your account. Please note that We make all User information accessible to Our employees, agents or partners and third parties only on a need-to-know basis and binds only its employees to strict confidentiality obligations. However, We are not responsible for the confidentiality, security or distribution of Your personal information by Our partners and third parties outside the scope of Our agreement with such partners and third parties.
- In case there is any breach of security, We will make all legally required disclosures concerning the breach and the confidentiality, or integrity of Your unencrypted electronically stored “personal information” to You via email or By posting it on Platform without any unreasonable delay, in as far as is consistent with any legitimate needs of law enforcement and any measures required to determine the scope of the breach and to safeguard the integrity of data.
- We at FinEzzy are committed about our client’s data and privacy. We blend security at multiple steps within our products with state-of-the-art technology to ensure our systems maintain strong security measures. The overall data and privacy security design allows us to defend our systems ranging from low hanging issue up to sophisticated attacks. You can read more about it https://www.finezzy.com/t-cs.
- If you are a security enthusiast or a researcher and you have found a possible security vulnerability on FinEzzy, we encourage you to report the issue to us responsibly. You could submit a bug report to us at info@radicaladvisors.com with detailed steps required to reproduce the vulnerability.
COMPLIANCES
We have implemented required Information Systems Management System policies and procedures in order to maintain industry standard best practices and applicable controls as necessary for protecting the data of Our Users.
FinEzzy’s use of information received from Google APIs will adhere to Google API Services
User Data Policy (‘https://developers.google.com/terms/api-services-user-data-policy’ additional_ requirements_for_ specific_api_scopes), including the requirements as necessary to the extent of adhering to the scope and policy.We will also be undergoing annual security assessment from a Google-designated third party and keep the same updated from time to time or as per instructions from Google and will publish the “letter of assessment” on FinEzzy website and mobile applications.
RETENTION PERIOD
We do not keep your personal data and information longer than necessary for the purpose of the processing except for any record retention required by applicable laws, including but not limited to Securities and Exchange Board of India (Investment Advisers) Regulations 2013, Insurance Regulatory Development Authority of India (Registration of Corporate Agents) Regulations 2015 and Prevention of Money Laundering Act 2002. This includes, for example, the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to carry out legal work, for the establishment or defence of legal claims. We may aggregate and anonymize your personal data and information (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you
CHANGES IN PRIVACY POLICY
We reserve the right to change the Policy at any time. You may note that this Policy itself and any such change of policy will be effective from the date of posting on the site.
Any changes shall be effective immediately upon the posting of the revised Privacy Policy. While We will make reasonable efforts to keep You posted on any updates to this privacy policy, to make sure that You are aware of any changes, We recommend that You review this policy periodically. If You are not comfortable with any of the changes to Privacy Policy, You may choose to discontinue usage of FinEzzy website or mobile applications. You can also email us at info@radicaladvisors.com to update or delete Your personal information that FinEzzy has collected.
