Privacy policy

KALEIDOFIN PRIVACY POLICY

Last Updated on Date: April 27, 2023

This Privacy Notice outlines Kaleidofin Private Limited’s approach to privacy of user data and to fulfil its obligations under applicable privacy laws in India. The provisions of this Privacy Notice are not applicable to collection/processing of data by the websites/applications of any of our franchisees, partners etc. and are restricted only to use of Kaleidofin’s website/applications.

This Privacy Notice is published in compliance with the following privacy laws:

India

  • Information Technology Act, 2000
  • Personal Data Protection Bill, 2019

This Privacy Notice may be further updated from time to time to ensure compliance with all applicable laws with respect to data privacy and protection, as may be applicable and notified by the relevant authorities from time to time.

This Privacy Notice applies to all your Personal Data processed by us, whether in physical or electronic mode.

For the purposes of this Privacy Notice, “Personal Data” shall mean data about or relating to a natural person who is directly or indirectly identifiable, having regard to any characteristic, trait, attribute or any other feature of the identity of such natural person, whether online or offline, or any combination of such features with any other information, and shall include any inference drawn from such data for the purpose of profiling.

Please note that this Privacy Notice is applicable to all instances where we play the role of a Data Fiduciary of your Personal Data, when we collect and process personal data about you for offering our products or services. There may be instances where we play the role of a Data Processor too, when we process Personal Data on behalf of another organization. In that case, the Privacy Notice of that organization becomes applicable to your Personal Data and the provisions of this Privacy Notice shall not apply.

Kaleidofin Private Limited is committed to keeping your Personal Data private. We process any Personal Data we collect from you in accordance with the applicable laws and regulations mentioned hereinabove and the provisions of this Privacy Notice. Please read the following carefully to understand our views and practices regarding your Personal Data and how we treat it.

Throughout this document, the terms “we”, “us”, “our” & “ours” refer to Kaleidofin Private Limited. And the terms “you”, “your” & “yours” refer to YOU (as the Data Principal).

WHAT PERSONAL DATA DO WE COLLECT & PROCESS?

Categories of Personal Data that we collect, and process are as follows:

  • Demographic & identity data (for e.g., name, email address, contact number, date of birth)
  • Financial data (for e.g., account details, payment details, invoice details, annual income, net worth, credit/ debit card details, details of your assets and liabilities)
  • Online identifiers and other technical data (for e.g., IP address, transaction logs, device details)
  • Health data (for e.g. Blood group)
  • Aadhar details (with your specific consent)
  • Other KYC related information (including but not limited to PAN Card and other identification details)

WHERE DO WE OBTAIN YOUR PERSONAL DATA FROM?

Most of the Personal Data we process is provided by you directly to us when you use our products and/or services. This also includes the Personal Data collected automatically and in the background by us when you use our website and application(s).

We may also receive Personal Data about you from third parties such as credit bureaus and financial services providers, KYC registration agencies, social media websites, Aadhaar ecosystem, account aggregator and other third party entities providing identity verification and fraud prevention services and other services as and when required by us.

HOW DO WE USE YOUR PERSONAL DATA?

We use your Personal Data for the following purposes:

  • To verify your identity;
  • To share it with third parties, including not limited to lenders, insurance companies, banks, mutual fund companies and their RTAs for the purpose of providing our services and fulfilling our other obligations;
  • To communicate with you regarding existing services availed by you, including notifications of any alerts or updates;
  • To evaluate, develop and improve our products and services;
  • For market and product analysis and market research;
  • To send you information about our other products or services which may be of interest to you;
  • To handle enquiries and complaints;
  • To send it to service providers for the purpose of validation and to comply with legal or regulatory requirements;
  • To validate KYC information shared by you, such as validation of PAN number details, physical verification of proof of address, validation of bank account information and KYC records with the banks; and
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud and situations involving potential threats to the safety of any person;
  • For employment purposes; and
  • To regulators, tax authorities & law enforcement agencies
  • For any other purposes as may be required by us to effectively deliver our services and carry out our functions and responsibilities as may be determined by us and subject to applicable laws.

LAWFUL BASES OF PROCESSING YOUR PERSONAL DATA

We process your Personal Data by relying on one or more of the following lawful bases:

  • You have explicitly agreed to/consented to us processing your Personal Data for (i) validation of such Personal Data as provided by you; (ii) sending it to third parties for the purpose of validation of such data; (iii) verification of your identity; and (iv) for sharing it with third parties to enable us to provide our services as provided under any other agreement executed between us for specific purposes;
  • The processing is necessary for employment purposes;
  • The processing is necessary for compliance with a legal obligation we have;
  • The processing is necessary for other reasonable purposes;

Where the processing is based on your consent, you have the right to withdraw your consent at any point in time. Please note that should the withdrawal of consent result in us not being able to continue offering our products and services to you, we reserve the right to withdraw or cease our products and services to you upon your withdrawal. You may withdraw your consent by contacting us with a written request to the contact details specified below in the ‘Contact Us’ section. Upon receipt of your request to withdraw your consent, the consequences of withdrawal will be communicated to you. Upon your agreement to the same, your request for withdrawal will be processed.

WHEN DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

We may use third parties in the provision of our products and services to you. We may share your Personal Data with such third parties. We have appropriate contracts in place with all such third parties. This means that they are not permitted to do anything with your Personal Data which is outside of the scope specified by us. They are committed to hold your Personal Data securely and retain it only for the period specified in our contracts with them.

1. Reasons for sharing your Personal Data with third parties:
We may disclose your Personal Data to third parties only where it is lawful to do so. This includes instances where we or they:

  • need to provide you with products or services
  • have asked you for your consent to share it, and you have agreed;
  • have a legitimate business reason for doing so;
  • have a legal obligation to do so. For e.g., to assist with detecting and preventing fraud;
  • have a requirement in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;

We may also disclose your Personal Data to appropriate authorities if we believe that it is reasonably necessary to comply with a law, regulation, legal process; protect the safety of any person; address fraud, security, or technical issues; or protect our rights or the rights of those who use our products & services.

2. With whom your Personal Data may be shared:
We may disclose your Personal Data to the following third parties:

  • any sub-contractors, agents or service providers (including but not limited to auditors, lawyers and other such professionals providing us specialised services) who work for us or provide services or products to us;
  • any third party institutions for research purposes/projects in collaboration with other institutions;
  • law enforcement authorities, statutory and regulatory bodies, government authorities, courts, dispute resolution bodies, auditors, investigating agencies and any party appointed or requested by applicable regulators to carry out investigations or audits of our activities and before whom it is mandatory to disclose Personal Data as per the applicable law, courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunals

CROSS-BORDER DATA TRANSFER

Subject to the provisions of applicable laws (including the laws mentioned hereinabove), Personal Data we hold about you may be transferred to other countries outside your residential country for any of the purposes described in this Privacy Notice, .

Please note that these countries may have differing (and potentially less stringent) privacy laws and that Personal Data can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process.

USE OF COOKIES AND OTHER TRACKING MECHANISMS

We may use cookies and other tracking mechanisms on our website and other digital properties to collect data about you.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information about your actions to the owners of the website.

Most web browsers allow you some control of cookies through browser settings.

Outlined below are the categories of cookies along with a description of what they are used for.

  • Strictly Necessary Cookies – These cookies are needed to run our website, to keep it secure and to comply with regulations that apply to us.
  • Functional Cookies – We may use functional cookies on our website. These cookies allow us to remember information you enter or choices you make (such as your username, language, or your region) and provide you with enhanced, more personalised features.
  • Performance/Analytics Cookies – We may use performance/analytics cookies on our website. These cookies collect information about how visitors use our website and services, including which pages visitors go to most often and if they receive error messages from certain pages. It is used to improve how our website functions and performs.

We may also use trackers (such as web beacons, tags, pixels) on our website and other digital properties to collect data about you.

We may also collect Personal Data about you via our mobile app(s) as well as the web app(s) via permissions in such app(s). This is primarily used to enhance the functionality of the app and to analyse it to serve you better.

HOW DO WE SECURE YOUR PERSONAL DATA?

We are committed to protecting your Personal Data in our custody. We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect your Personal Data from unauthorized access, alteration, transmission, and deletion. We ensure that the third parties who provide services to us under appropriate contracts take appropriate security measures to protect your Personal Data in line with our policies.

However, while we strive to use commercially acceptable means to protect your Personal Information, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, by using this Website, our mobile app(s) and web app(s) you agree that we will have no liability for disclosure of your Personal Information due to errors in transmission, infrastructure failures by us or any intermediary (including telecom and internet service providers), or unauthorized acts of third parties.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We keep the Personal Data we collect about you for as long as it is required for the purposes set out in this Privacy Notice and for legal or regulatory reasons. We take reasonable steps to delete or permanently de-identify your Personal Data that is no longer needed.

CHILDREN’S PRIVACY

We do not knowingly collect Personal Data from children. If you are a parent or guardian and aware that your Child has provided us with Personal Data, please contact us using the details in the ‘Contact us’ section of this notice.

CONTACT US

For any further queries and complaints related to privacy, or exercising your rights, you could reach us at:
Contact Email Address: 121@kaleidofin.com

NOTIFICATION OF CHANGES

We regularly review and update our Privacy Notice to ensure it is up-to-date and accurate. Any changes we may make to this Privacy Notice in future will be posted on this page.

YOUR PRIVACY RIGHTS

If you are an Indian resident, you have the following rights and we commit to provide you with the same:

  • You have the right to get confirmation and access to your Personal Data that is with us along with other supporting information.
  • You have the right to ask us to rectify your Personal Data that is with us that you think is inaccurate. You also have the right to ask us to update your Personal Data that you think is incomplete or out-of-date.
  • You have the right to withdraw your consent provided to us for processing and sharing of your Personal Data. Upon your request of such withdrawal, we shall promptly return/delete/de-identify (as may be feasible) all your Personal Data belonging with us. However, we shall no longer be able to provide you our products/services upon withdrawal of such consent by you.
  • Under the IT rules we are obliged to provide you with a readable copy of the Personal Data you have provided us. If you would like a copy, do get in touch with us at 121@kaleidofin.com.

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