Privacy Policy

Last Updated: 1st January 2024

ICEBERG TRIBE LLP is the author and publisher of the haarmoney website and Mobile Website, Application (“website/ App”) through which you have opted to avail of certain Services by agreeing to the terms of use (“Terms of Use”), available on the home screen of the Website, App. For the purposes of this Privacy Policy, unless defined hereunder, all capitalised terms shall have the meanings ascribed to them in the Terms of Use. When You share information with Us, we are able to make Our services even better. As You use Our Services, we want You to be clear on how We’re using information and the ways in which You can protect Your privacy. This Privacy Policy (“Privacy Policy”) is published in compliance with inter alia: a. Section 43A of the Information Technology Act, 2000 (“IT Act”); b. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”); and c. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011. Our Privacy Policy explains: (i) What information We collect; (ii) How We collect and use that information; (iii) How You can provide information selectively, and how You can access and update this information; and (iv) How We process, share and protect Your information This Privacy Policy applies to all Users accessing or using Our Website, App. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, IN PART OR AS A WHOLE, DO NOT USE THE WEBSITE, APP OR SERVICES PROVIDED ON THE WEBSITE, APP, OR PROVIDE US WITH ANY OF YOUR INFORMATION.

1. Information We Collect

We collect the following types of information about You, both through offline documentation that you may fill, as well as when You use Our Website, App: Demographic Information, Behavioural Information, and Indirect Information, (as defined below, and collectively, “Information”). Additionally, We also collect Account Information and Personal Information (as defined below) from You. We collect Your Information and Account Information either directly from You through forms on the Website, App or indirectly by using different technologies. We collect Personal Information (as defined below) from the mobile (with necessary permissions) or when it is directly taken from you. Demographic Information We may collect from You, information which is not unique to You and refers to selected population characteristics (“Demographic Information”) including age, gender, location and occupation, preferences and interests. We may also collect information about how You use the Website, App and information about Your mobile device and software including usage statistics, traffic data, Your IP address, browser and operating system type, domain names, access times, locations, Your previous orders and transactions including the product and pricing details, transaction information and payment and browsing history (“Behavioural Information”). Your use of certain third party services on the Website, App also requires Us to collect such information as is considered necessary for that purpose (“Indirect Information”). In order to avail of or use Our Service, You are required to provide Us with Your details, including but not limited to: Your name; date of birth; mobile number; email address; PAN Number; a password created by You, and details required in the Account section. You will also be required to share details on your income, expenses, future goals, risk appetite, and other money related information (collectively, “Account Information”). The IT Act and the SPDI Rules regulate the collection, usage, retention and disclosure of personal information, which is defined under the SPDI Rules as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person. The SPDI Rules further define “Sensitive Personal Data or Information” (“SPDI”) of a person as personal information about that person relating to: i. passwords; ii. financial information such as bank accounts, credit and debit card details or other payment instrument details; iii. physical, physiological and mental health condition; iv. sexual orientation; v. medical records and history; vi. biometric information; vii. any detail relating to the above clauses as provided to the body corporate for providing services; and viii. any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise. In addition to your Account Information, you will also need to provide us with your bank account details, credit and debit card details or other payment instrument details (in respect of the payment instrument you wish to use to make the payment for availing the Paid Service). Such bank account details, credit and debit card details or other payment instrument details including details submitted pursuant to your KYC Form (“Personal Information”), correspond with some of the categories enumerated above, are classified as SPDI, and treated as such under this Privacy Policy. This shall also include information taken from mobile device like email address, contacts, SMS, etc with prior consent from you. All Account Information and Personal Information is provided by You to Us voluntarily. Collection, use and disclosure of Personal Information requires Your express consent. By providing us with Personal Information, You are providing us with Your consent to Our use, collection and disclosure of the Personal Information. The Personal information as defined above like can be shared or uploaded to third party service providers as governed by this Privacy Policy. You may choose to not provide Us with any or all information included under Account Information and Personal Information, but in the event that You do so, We will be unable to provide You with Our Service.

2. How We Use Your Information

We use Your Information for the following purposes: a. To operate and improve the Website, App in order to foster a positive User experience and to improve our business as a whole; b. Analysing data, tracking trends, building algorithms, creating databases for rating systems, recommendations engines, etc.; c. Research; d. For non-targeting reasons such as frequency capping, compliance, billing, ad reporting or delivery, market research or product development purposes; e. To conduct audits and quality assessment procedures; and f. To analyse the use of Our resources, troubleshooting problems and improving Our Services, by using the information regarding Your mobile device and software. In addition to the above, We also use your Information, Account Information and Personal Information for the following purposes: g. To provide Our Paid Service to You, including by creating, retaining and analyzing your financial or Investment Profile, Parameters and other relevant information; h. To facilitate the opening of an account for the undertaking of any Transactions chosen by You, i. To provide any and all information that may be required by Us, from time to time, in compliance with existing legal norms and regulations, including but not limited to contact information, address and tax related information and any information required under existing or future KYC norms and laws or as may be deemed necessary to authenticate Your profile or any action taken using Your Account; j. To comply with Applicable law; k. Contacting Users for offering new products or services; l. To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of Our Terms of Use, or as otherwise required by law; m. To respond to any queries that You may have, and to communicate information to You, including notifications of any promotions or alerts, any updates to the Website, App, or the introduction of any future fees or charges that We may collect at the time for the provision of Our Services to You. n. To contact You from time to time to record Your valuable feedback on Our Services, as they currently stand, and/or any potential Services that may be offered in the future. (Collectively, the above constitute “the Purposes”).

3. Cookies and Other Tracking Technologies

We utilize “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Website, App. Some cookies and other technologies may serve to recall information previously indicated by a User. Most browsers/mobile settings allow You to control cookies, including whether or not to accept them and how to remove them. You may set most browsers/mobile website, Application to notify You if You receive a cookie, or You may choose to block cookies with Your browser/mobile website, Applications. Tracking technologies may record information such as internet domain and host names, internet protocol (IP) addresses, browser software and operating system types, stream patterns, and dates and times that Our Website, App are accessed. Our use of cookies and other tracking technologies allows Us to improve Our Website, App and Your experience. At all times, You may refuse all cookies on your device, Application by changing your device settings to the extent permissible on Your device. However, by doing so, You may not be able to use certain features on the website, Application You visit or take full advantage of all the website, Application offerings and interest-based advertising. You can remove cookies by following directions provided in your device’s “help” file.

4. Sharing Your Information

We disclose Your Information, Account Information or Personal Information, as the case may be to third parties in the manner specified below: a. Disclosing Your Information, Account Information and Personal Information to companies and individuals who are authorised by Us to perform functions, including Our associates or agents or partners or third party service providers; b. We may share Your Information and Account Information with Our partners, affiliates, investors, stakeholders or potential associates in an anonymized and aggregate manner, so that they too may understand how Users use Our Website, App, and enable Us to create a better overall experience for You. c. We also share aggregated anonymous information about Users with Our clients, partners, other Website, App Users, and other third parties so that they may be aware of the nature and number of Users using the Website, App, in order for them to be able to serve advertisements and other kinds of marketing information that may be relevant for You on Our Website, App; d. We may disclose and transfer Your Information, Account Information and Personal Information to a third party who acquires, or may potentially acquire, Our business, whether such acquisition is by way of a merger, consolidation or purchase of all or a substantial portion of Our assets; e. We may transfer Information, Account Information and Personal Information to a third party, including persons outside India, to improve the Services; and f. We will disclose Your Information, Account Information and Personal Information if legally required to do so, pursuant to an order from a governmental entity or in good faith. We will disclose the Information to: i. Conform to legal requirements or comply with legal process; ii. Protect Our rights or property or Our affiliated companies; iii. Prevent a crime or protect national security; or iv. Protect the personal safety of Users or the public. Such third parties may include: • Our associates, affiliates or related entities; • Any of our agents, contractors or third party service providers that process or will be processing Your Information, and relevant Account Information or Personal Information on Our behalf, including but not limited to those which provide administrative or other services to Us such as mailing houses, telecommunication companies, information technology companies and data centres; and • Third parties, to whom disclosure by Us is for one or more of the Purposes and such third parties would in turn be collecting and processing Your Information, Account Information and Personal Information for one or more of the Purposes. Subject to Applicable law, We may at Our sole discretion, transfer Personal Information to any other body corporate (as defined under the Information Technology Act, 2000) that ensures at least the same level of data protection as is provided by Us under the terms hereof, located in India or any other country. By using the Website, App, You accept the terms hereof and You hereby consent to the storage and processing of Personal Information in any of the above locations. By continuing to use the Website, App, You provide Your consent for transfer, sharing and disclosure of such Information, Account Information and Personal Information by Us in accordance with this Privacy Policy. Any third party to which We transfer or sell Our assets, merge or consolidate with, will have the right to continue to use the Information, Account Information and Personal Information provided to Us by You, in accordance with the Terms of Use and this Privacy Policy.

5. Security

We endeavour to maintain physical, technical and procedural safeguards that are Appropriate to protect your Information against loss, misuse, copying, damage or modification and unauthorized access or disclosure. Some of the security measures adopted by Us are: • We review Our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems; and • We restrict access to Personal Information, to Our employees and agents who need to know that information in order to process it for Us, and who are subject to strict contractual confidentiality obligations, and may be disciplined or whose relationship with Us may terminate if they fail to meet these obligations. No employee or administrator of the Company will have knowledge of Your password. It is important for You to protect against unauthorized access to Your password and Your mobile phone. Be sure to log off from the Website, App when finished. We do not undertake any liability for any unauthorised use of Your Account and password. If You suspect any unauthorized use of Your Account, You must immediately notify Us. You shall be liable to indemnify Us due to any loss suffered by Us due to such unauthorized use of Your Account or password. Further, We shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond Our reasonable control including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User, etc. Retention of Information We will also put in place measures such that Your Account Information and Personal Information, which is in Our possession or under Our control, is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the Purpose for which that Account Information or Personal Information were collected is no longer being served by the retention of such Account Information or Personal Information; and (ii) retention is no longer necessary for any other reason. If You wish to cancel Your account, or request that We no longer use Your Account Information and Personal Information to provide You Services, contact Us. If You wish to delete Your Account, and thereby discontinue using Our Service, you may do so at any time, in accordance with Our Terms of Use. We, however, reserve the right to retain, store and use Your Information, Account Information or Personal Information or content for Our business purposes, whether such Information or Your Account has been deleted or not. After a period of time, Your data may be anonymized and aggregated, and then may be held by Us as long as necessary for Us to provide Our Services effectively, but Our use of the anonymized data will be solely for analytic purposes. Please note that Your withdrawal of consent or cancellation of Account may result in Us not being able to provide You with Our Services, or terminate any existing relationship that We may have with You.

6. Disclaimer

We cannot ensure that all of Your Information, Account Information or Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although We are committed to protecting Your privacy, We do not promise, and You should not expect, that Your Information or private communications will always remain private. As a User of the Website, App, You understand and agree that You assume all responsibility and risk for Your use of the Website, App, the internet generally, and the information You post or access and for Your conduct on and off the Website, App.

7. Indemnity

You agree and undertake to indemnify Us in any suit or dispute by any third party arising out of disclosure of information by You to third parties either through Our Website, App or otherwise and Your use and access of websites, website, Applications and resources of third parties. We assume no liability for any actions of third parties with regard to Your Information, Account Information or Personal Information which You may have disclosed to such third parties.

8. Severability

Each clause of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other clauses herein except where otherwise expressly indicated or indicated by the context of the Privacy Policy. The decision or declaration that one or more of the clauses are null and void shall have no effect on the remaining clauses of this Privacy Policy.

9. Changes to this Privacy Policy

We reserve the right to update, change or modify this Privacy Policy at any time. The Privacy Policy shall come to effect from the date of such update, change or modification. If You continue to access or use the Website, App even after any such changes have been made, it would be deemed to be Your implied consent to the changed Privacy Policy.