Privacy Policy

This privacy policy (“Policy”) explains Our policy regarding the collection, use, disclosure and transfer of Your information [provided by You on Our website ‘www.fintso.com’ or through another URL, and/or mobile applications ‘Fintso’ and ‘Fintso Partner’ (collectively referred as the Fintso Platform)] to “Adapt Fintech Advisors Private Limited”. and/or its parent entity, subsidiary(ies) and/or affiliate(s) (collectively referred to as the " Company "), which operates various websites, including sub-sites, platforms, applications, m-web platforms and other platforms, including the Fintso Platform, (collectively referred to as "Sites") for delivery of information, products, offerings and content via any mobile or internet connected device or otherwise (collectively the "Services"). The Company is the licensed owner of the Fintso Platform and develops, manages, and operates the Fintso Platform and other Sites and the Company has permitted its group companies and subsidiaries to use the Fintso Platform for their respective products and services. This Policy forms part and parcel of the Terms of Use and other terms on the Fintso Platform ("Terms of Use"). The Privacy Policy should always be read in conjunction with the Terms of Use. Capitalized terms which have been used here but are undefined shall have the same meaning as attributed to them in the Terms of Use and Agreements entered by and between the Company, its Users or customers of Users, if any. This Policy should always be read along with Terms of Use and specific products and services related Terms & Conditions and Agreements (hereinafter referred to as Terms and Conditions).

This Privacy Policy is also applicable to Company's subsidiaries, affiliates and group companies which provide their products and services on the Fintso Platform.

This Privacy Policy is applicable to a User who avails the Services. The term "User" for the purposes of this Privacy Policy shall mean You, in the capacity of an individual, a guest user, browser and/or representative of an entity, who visits, accesses, uses, downloads, deals with, avails Services and/or transacts through Fintso Platform. For the purpose of this Policy, wherever the context so requires "You" or "Your" shall mean the User and the term "We","Us"," Our " shall mean the Company.

In case You do not wish to provide any information, including personal or personally identifiable information, or in the event You do not agree to any or all the clauses of the Terms of Use, Privacy Policy and product specific Terms and Conditions, then the Company may not be in a position to offer You all or some of the products and services, including without limitation, certain features of the Fintso Platform, and may even restrict (partially or fully) the User from accessing the Fintso Platform. Further, if You do not agree to this Privacy Policy, Terms of Use and/ or product specific Terms and Conditions, You may also not register on Fintso Platform, not avail Our Services and/or deregister from the Fintso Platform and stop using Our products and services. We shall not be held responsible and/or liable for any denial of Service due to Users not providing the required information.

You must be a natural person who is at least 18 (eighteen) years of age. You must not misrepresent Your identity. The right to use the Fintso Platform is personal to the User and is not transferable to any other person or entity. The Company and/or its Group Companies presume adequate and lawful parental consent in case the Personal Information is shared by a User under the age of 18 years.

As We update, improve, and expand the Services, this Policy may change, so please refer back to it periodically. By accessing and using the Sites or otherwise using the Services, You consent to collection, storage, and use of the personal information You provide (including any changes thereto as provided by You) for any of the Services that We provide.

The Company respects the privacy of the Users of the Services and is committed to protect it in all respects. The information about the User as collected by the Company is: (a) information supplied by Users; (b) information automatically tracked while navigation; and (c) information collected from any other source (collectively referred to as "Information").

1. Information received, collected, and stored by the Company

While registering on or accessing the Fintso Platform or while using Our Services, You may be required to provide, some information about yourself, on a voluntary basis. We may also ask You to provide certain additional information on from time to time or retrieve information about You from third parties. All information disclosed by You shall be disclosed willingly on a voluntary basis and without any coercion. Also, in some instances You might have to provide certain information on a mandatory basis (such as KYC information).

A. Information supplied by users

The Company shall collect Personal Information about the User, including, without limitation, at the time of:

  1. Registering or setting up an account on the Fintso platform.
  2. While filling up forms.
  3. Browsing or accessing the Fintso platform.
  4. While availing any products or services.

Users may be required to provide certain personal information for the registration process that may include but not limited to:

  1. Name;
  2. PAN;
  3. Email ID;
  4. Mobile number;
  5. Marital status;
  6. Bank account number;
  7. Address;
  8. Medical records and history;
  9. Nominee details;
  10. Date of birth;
  11. Signatures;
  12. Income Details;
  13. Documents (like Address proof or Bank Statements) and other related information.

The Company shall also collect non-personal information pertaining to the behaviour of the User (behavioural information), while using or browsing through the Fintso Platform, messages posted by the User on the Fintso Platform, etc.

When You register using Your other accounts like from Facebook, Twitter, Google, etc. we shall retrieve information from such accounts to continue to interact with You and to continue to provide the Services.

Any personally identifiable information provided by You will not be considered as sensitive if it is freely available and/or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, Twitter, etc. Further, anything posted, uploaded, conveyed, or communicated by users on the public sections of the Sites becomes published content and is not considered personally identifiable information subject to this Privacy Policy. The Company, and its partners, vendors, service providers, etc. may also contact You from time to time through any mode of communication about updating Your personal information in order to provide the Users with such features that We believe may benefit or interest You.

The Personal Information, any non-personal information and behavioural information is stored by the Company on servers owned by it or its group companies or by third parties in India.

Voluntary information

We may collect additional information at other times, including but not limited to, when You provide feedback, comments, change Your content or email preferences, respond to a survey, or any communications with Us. However, in the event You wish to provide Us with Your Aadhar card information, You hereby agree and acknowledge that You are providing the same to Us purely on a voluntary basis only.

B. Information automatically collected or tracked during navigation

Cookies

To improve the responsiveness of the Sites for Our Users, We may use "Cookies", or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (User ID) to understand the User's individual interests using the identified computer or device. Unless You voluntarily identify Yourself (for example - through registration), We will have no way of knowing who You are, even if We assign a cookie to Your computer or device. The only personal information a cookie can contain is information You supply. A cookie cannot read data off Your hard drive or device. Our advertisers may also assign their own cookies to Your browser (if You click on their ads, etc.), a process that We do not control. We receive and store certain types of Information whenever You interact with Us via Our Site or Service though Your computer, laptop, netbook, mobile phone, tablet, or any other handheld device, etc.

Log File Information

We automatically collect limited information about Your computer's connection to the Internet, mobile number, including Your IP address, when You visit Our site, application, or service. Your IP address is a number that lets computers attached to the Internet know where to send Your data, such as the pages You view. We automatically receive and log information from Your browser, including but not limited to Your IP address, Your computer's name, Your operating system, browser type and version, CPU speed, and connection speed. We may also collect log information from Your device, including Your location, IP address, Your device's name, device's serial number or unique identification number (e.g. UDID on Your iOS device).

Clear GIFs

We may use "clear GIFs" (Web Beacons) to track the online usage patterns of Our Users in an anonymous manner, without personally identifying the User. We may also use clear GIFs in HTML-based emails sent to Our Users to track which emails are opened by recipients. We use this information to inter-alia deliver Our web pages to You upon request, to tailor Our Sites or Service to the interests of Our users, to measure traffic within Our Sites to improve the quality, functionality and interactivity of Our Sites and let advertisers know the geographic locations from where Our Users come without personally identifying the Users.

2. Information from other Sources:

We may receive information about You from other sources, including, without limitation, such as KRA, CKYCR, Credit Bureaus, and add it to Our account information and treat it in accordance with this Policy. If You provide information to any of Our vendors, service providers, partners (such as payment gateway providers), agencies etc., who provide services to Us, Your account information and order information may be passed on to Us.

Demographic and other information:

We may refer other sources of demographic and other information to provide You with more targeted communications and promotions. We use Google Analytics, among others, to track the user behaviour on Our Sites. Google Analytics specifically has been enabled to support display advertising towards helping Us gain understanding of Our users' demographics and interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that You may have shared with Us. You can opt-out of Google Analytics for display advertising and customize Google Display Network ads using the Ads Settings options provided by Google.

Links to third party sites or ad-servers

The Sites may include links to other websites or applications. Such websites or applications are governed by their respective privacy policies, which are beyond Our control. Once You leave Our servers (You can check where You are by checking the URL in the location bar on Your browser), use of any information You provide is governed by the privacy policy of the operator of the application, you are visiting. Their privacy policy may differ from Ours. If You can't find the privacy policy of any of these sites via a link from the application's homepage, You should contact the application owners directly for more information. We do not provide any personally identifiable Information to third party websites, applications, advertisers, or ad-servers without Your consent except in the circumstances mentioned in Information Sharing section.

When We present Information to Our advertisers – to help them understand Our audience and confirm the value of advertising on Our Sites – it is usually in the form of aggregated statistics on traffic to various pages or content within Our Sites. We use third-party advertising companies to serve ads when You visit Our Sites. These companies may use Information (excluding Your name, address, email address or telephone number or other personally identifiable information) about Your visits to this and other websites or application, in order to provide advertisements about goods and services of interest to You.

Information used by the company

The Personal Information provided by the User is used by the Company for the purposes, including, without limitation:

  • Provide a smooth, safe and customized experience to the User on the Fintso Platform;
  • Provide and promote its products and services on the Fintso Platform, general as well as customized, and improve the same from time to time;
  • Provide You the most user-friendly experience and for developing new services;
  • Analyse flow, track user trends, measure promotional effectiveness;
  • Provide additional features on the Fintso Platform through Cookies;
  • Protect the safety and integrity of the Fintso Platform, information and maintain the confidentiality of the User and their data;
  • Ensure smooth execution of transaction and payments;
  • Maintain, improve and provide Service (including personalization of the Fintso Platform);
  • Inform the User about new or change in products, services, offers, updates, reminders, billing information, customer service(s), etc.;
  • To detect and/or prevent any fraudulent, criminal, and/or prohibited activity on the Fintso Platform;
  • To process Your request or respond to Your queries, grievances, and comments;
  • Send customized messages and notifications to You;
  • Communicate any change in Our products, services, Terms and Conditions, Privacy Policy;
  • Marketing and commercial communications regarding products and services;
  • Analyse Your behaviour on the Fintso Platform;
  • Facilitate Company's marketing, advertising and educational activities and initiatives;
  • Audit and investigate;
  • Update regarding third party services and products and services offered on other Sites;
  • Data analysis or analytics;
  • Pre-fill various forms;
  • Maintain User accounts;
  • Provide general information or updates.

We may also use Your email address or other personally identifiable information to send commercial or marketing messages about Our Services and/or such additional updates and features about third parties' products and services with an option to subscribe or unsubscribe. We may, however, use Your email address for non-marketing or administrative purposes (such as notifying You of major changes, for customer service purposes, billing, etc.).

3. Information sharing

  • The Company may share Your Information with authorised third parties without obtaining the prior consent of the User in the following circumstances but not limited to:
  • To provide a seamless experience
  • To provide various products and services to the User of the Company as well as of the third parties
  • Customize offers, products and services based on the User needs or behavioural pattern
  • Ensure smooth execution of transactions and payments
  • To protect the rights and properties of the Company
  • To initiate and investigate any complaints, claims or disputes
  1. 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 but not limited to 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 or for complying with the applicable laws and regulations.
  2. The Company proposes to share such Information to conduct its business and to share such Information 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 Policy and any other appropriate confidentiality and security measures.
  3. The Company may present Information with third parties – to help them understand Our audience and confirm the value of advertising on Our Sites – however it is usually in the form of aggregated statistics on traffic to various pages within Our site. We use third-party advertising companies to serve ads when You visit Our Sites. These companies may use Information (excluding Your name, address, email address or telephone number or other personally identifiable information) about Your visits to this and other websites or application, in order to provide advertisements about goods and services of interest to You.

    We also share User Personal Information with Our vendors and service providers – to help Us understand about Our User Behaviour and/or to serve ads when You visit Fintso platform. These companies may use Information (excluding Your name, address, email address or telephone number or other personally identifiable information) about Your visits to this and other websites or application.

  4. The Company may share Your Information regarding Your activities on Sites with third party social websites to populate Your social wall that is visible to other people however You will have an option to set Your privacy settings, where You can decide what You would like to share or not to share with others.
  5. We may share Your Information to enforce or protect Our rights or any or all of its affiliates, associates, employees, directors or officers or when We have reason to believe that disclosing Information of User(s) is necessary to identify, contact or bring legal action against someone who may be causing interference with Our rights or Our Sites, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
  6. We may share information with consultants, third parties, business partners and vendors for providing Our and/or their various products and services. The handling of Your Information by such consultants, third parties, business partners and vendors shall be as per the privacy policies of those consultants, third parties, business partners and vendors. The Company shall not be responsible or liable for any action or omission of these consultants, third parties, business partners and vendors with respect to Your Information.

4. Data accessed from Google

Whenever we access your personal information or data automatically from Google, with your consent, the policy governing the access and use of the data will be as follows:

  • The Company will be accessing your data, from Google, for tracking of User's financial transactions to provide the requisite service offered from time to time.
  • The Company shall only read relevant emails of the User sent by financial service providers by identifying the Sender of emails such as @camsonline.com, @kfintech.com, @franklintempleton.com.
  • The Company does not access any other email of the User.
  • The Company does not open, read, or access any personal mail including User's personal information.

The Company may share your Data (accessed from Google) with our affiliates, service providers, or regulators:

  • To provide seamless, smooth, safe, and customized experience to the User
  • When it is requested or required by law
  • To initiate any investigate any complaints, claims or disputes
  • To customize products or introduce new products
  • To improve the user facing features,

For the sake of clarity, the Company does not sell, transfer, or lease such information for serving ads.

5. Data accessed from Google Drive

The Company via its Sites shall require access to your Google Drive to upload, download, and delete documents within the Sites. These documents will be used solely within the Sites domain and will not be shared with any third parties. No other files except the ones uploaded by the Company through the Sites can be deleted from such Sites. The data is also not used for any AI related purpose.

The Sites use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

6. Accessing and updating personal information

When You use the Services or Sites (or any of its sub sites), We make good faith efforts to provide You, as and when requested by You, with access to Your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where We provide information access and correction, We perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way We maintain certain services, after You delete Your information, residual copies may take a period of time before they are deleted from Our active servers and may remain in Our backup systems.

We encourage You to review, update and correct the personal information that We maintain about You, and You may request that We delete personal information about You that is inaccurate, incomplete or irrelevant for legitimate purposes, or are being processed in a way which infringes any applicable legal requirement.

Your right to review, update, correct etc. Your information is subject to Our records retention policies and applicable law, including any statutory retention requirements.

Retention of Data

We shall retain the records as per applicable laws and such other statutory or regulatory requirements from time to time. In the event any legal or regulatory proceeding is pending, we can retain records for a longer period. We shall store the data, information, and records on a server owned by Us or Our group companies in India.

We may keep Our records of the electronic instructions or transactions in any form as permitted under applicable Laws. In this regard, all records, whether in electronic form, magnetic form, documents or any other form with respect to electronic instructions or online transactions shall be conclusive evidence of such instructions or transactions and shall be binding on the User.

7. Information Security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of Our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where We store personal data. All information gathered is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, as effective as Our security measures are, no security system is impenetrable. We cannot guarantee the security of Our database, nor can We guarantee that information You supply will not be intercepted while being transmitted to Us over the Internet. And, of course, any information You include in a posting to the discussion areas is available to anyone with Internet access.

8. Updates and Changes

The internet is an ever-evolving medium. We may alter Our Policy from time to time to incorporate necessary changes in technology, applicable law or any other variant. In any case, We reserve the right to change (at any point of time) the terms of this Policy or the Terms of Use. Any changes We make will be effective immediately on notice, which We may give by posting the new policy on the Sites. Your use of the Sites or Services after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform You via electronic mail. In any case, You are advised to review this Policy periodically on the Sites to ensure that You are aware of the latest version.

9. Questions and Grievance Redressal

Redressal Mechanism: Any complaints, abuse or concerns with regards to the use, processing and disclosure of Information provided by You or breach of these terms should immediately be informed to the designated Concerned Officers, in writing or through email to:

We request the User to provide the following information in their complaint:

  • Clear statement as to whether the information is Personal Information or Sensitive Personal Information.
  • User address, telephone number or e-mail address.