A. Introduction

This Privacy Policy (“Policy”) describes our policies and procedures on the collection, use, disclosure, and protection of your information when you use our services. We at Growzen Financial Services Private Limited are committed to protecting your privacy online and recognize your need for appropriate protection and management of any information you share with us.

By accessing or using our platform, you agree to the collection and use of information in accordance with this Policy.

This Policy is an electronic record under the Information Technology Act, 2000 and does not require any physical, electronic, or digital signature. It forms part of our Terms of Use and in case of any conflict between this Policy and the Terms of Use, our interpretation will be final and binding.

By accessing or using our website/application, you provide your free, specific, informed, and unambiguous consent to the collection and use of information as described in this Policy. If you provide information about someone else, you confirm that:
(a) the information is accurate and up-to-date;
(b) they know you have shared their information with us; and
(c) they consent to us using their information as outlined in this Policy.

For the purposes of this Policy, any information provided by you relating to someone else, shall be considered as the information of the User.

This Policy applies to everyone who accesses our website/application and explains what information we collect, how we use it, who we share it with, and how we protect it. We respect your privacy and will not distribute your personal information indiscriminately or use it in ways you would not expect.

B. Definitions

The website/application including the Growzen Financial platform (“Platform”) is owned, operated and maintained by Growzen Financial Services Private Limited (“Company”). Throughout this Policy, users of the services and other persons who may visit the Platform will be referred to as “User”.

In the course of using the Platform which includes, but is not limited to, any of the websites/applications under the Growzen Financial domain or availing the products and services vide the online application forms and questionnaires, online consents and such other details required from time to time on the Platform, the Company and/or its affiliates may become privy to some of User’s personal information, including which may or may not be of confidential nature. The Company is strongly committed to protect the privacy of its Users and has taken all necessary and reasonable measures to protect the confidentiality of any customer information.

By visiting/setting up an account on the Platform, the User accepts and agrees to be bound by this Policy. The User agrees to provide the information to the Company and allows the Company to use such information in accordance with this Policy. This Policy specifies the manner in which personal data and other information is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company. This Policy does not apply to information that User provides to, or that is collected by, any third-party (excluding the Company or its affiliates) through the Platform, and any third-party sites that User accesses or uses in connection with the services offered on the Platform. If the User does not agree to any of the terms in this Policy, the User may not access or use the website/application. By setting up/creating an account on the Platform/accessing the website/application, the User signifies her/his acceptance to the provisions of the Policy and agrees to provide the information and allow using such information in accordance with this Policy.

The terms not defined herein shall have the same meaning ascribed to them under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”).

C. Information Collection

The Company may collect User Data (as defined hereinbelow) when the User visits, registers or sets up an account on the Platform. The User may browse certain sections of the Platform without being a registered member, however, to avail certain services on the Platform, the User is required to register with the Company.

The following information (“User Data”) may be collected from the User:

1. While registering on the Platform, the User may provide the information/documents which, inter alia, includes mobile number, email address, password, date of birth, gender, Permanent Account Number (PAN), passport or any other evidentiary document, signature, marital status, nominee details, financial information such as billing address, bank account details, credit card number, expiration date and/or other payment related details or other payment method data. All information disclosed by the User shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/genuineness/misrepresentation/fraud of the information/documents shared by the User shall be on the Company nor it be in anyway responsible to verify any information/documents obtained from the User.
2. The Company may ask the User to provide certain additional information, including but not limited to additional identity proof, alternative methods of communication, etc., on a case to case basis.
3. The Company or its affiliates may retrieve User’s records available with third party including from Know Your Customer (KYC) Registration Agency (KRA) such as name, address proof, identity proof, father’s name, occupation, address or any other KYC details.
4. The Platform may collect and process information pertaining to clients of Users in connection with the distribution of products or services via the Platform. Such information may include, but is not limited to:
   (a) Personal Identification Data: Names, addresses, contact numbers, email addresses, and demographic information of clients.
   (b) Transactional Data: Details of products or services purchased or distributed, dates of transaction, payment information, and transaction histories.
   (c) Usage Data: Information regarding interactions with the Platform, such as log data, device information, and activity logs associated with registered products or services.
   (d) Communications Data: Records of communications and support requests submitted by clients regarding distributed products or services.
   (e) Any Other Information: Any data provided by Users regarding their clients for the purpose of supporting, registering, or servicing distributed products.
5. Such information as referred to in paragraph 4 above is collected for the following purposes:
   (a) To enable and administer the distribution of products or services through the Platform.
   (b) To facilitate after-sales service, support, and client communications.
   (c) To monitor and improve the quality, security, and performance of the Platform.
   (d) To comply with applicable legal or regulatory requirements.
   (e) To facilitate the usage of the Platform for the User.
6. If the User downloads and/or uses the Platform through his/her mobile, the Company may receive information about mobile’s location, the mobile device, including a unique identifier number for the device. The Company may use this information to provide the User with location-based services including, but not limited to, search results and other personalized content. The User can withdraw his/her consent at any time by disabling the location-tracking functions on the mobile. However, this may affect the performance of certain functionalities on the Platform.
7. All transactional information including financial information gathered by the Company shall be stored on servers, log files and any other storage system owned by the Company.
8. The Company may also collect certain non-personal information, such as User’s internet protocol address, web request, operating system, browser type, uniform resource locator, internet service provider, aggregate user data, browser type, software and hardware attributes, pages he/she requests, cookie information, etc. which will not identify with the User specifically, while he/she browses, accesses or uses the Platform. The Company receives and stores such data, using data collection devices such as “cookies” on certain pages of the Platform, in order to help and analyze its webpage flow, track user trends, measure promotional effectiveness, and promote trust and safety. The Company offers certain additional features on the Platform that are only available through the use of a “cookie”. It places both permanent and temporary cookies in User’s machine’s hard drive.
9. The Company may use data collection and tracking tools such as web beacons, pixel tags, embedded links, cookies, and other similar tracking techniques. Cookies allow the User to enter his/her password less frequently during a session on the Platform. Most cookies are “session cookies” which are automatically deleted from User’s hard drive at the end of a session. The User is always free to decline Company’s cookies if his/her browser permits, although in that case, the User may not be able to use certain features or services being provided on the Platform or he/she may be required to re-enter his/her password each time he/she logs in or access the Platform during a session.
10. The Company may automatically track certain information about the User based upon his/her behaviour on the Platform. The Company uses this information to do internal research on the User demographics, interests, and behaviour to better understand, protect and serve them. This information is compiled and analysed by the Company on an aggregated basis and not individually, in a manner that does not specifically identify the User.
11. If the User chooses to post messages on our message boards, chat rooms or other message areas or leave feedback, the Company will collect and store such information that the user provides to it- makes it liability of the user to provide correct info. The Company retains this information as necessary to resolve disputes, provide customer support, respond to queries and inquires, and troubleshoot problems and improve the services.
12. If the User sends correspondence to the Company, such as emails or letters, or if other users or third parties send correspondence about User’s activities, the Company may collect and retain such information into a file specific for responding to User’s request and addressing concerns in relation to User’s use of the Platform. The Company shall be entitled to retain User Data and other information for such duration as may be required for the purposes specified hereunder and will be used by the Company only in accordance with this Policy.
13. Users engaged with the Company or its affiliates may provide financial and distribution services through the Platform in accordance with applicable laws and in accordance with their agreement with the Company. The information used by the Company from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. Your information related to distribution activities gets automatically updated on the Platform. You can also delete or modify the information by mailing to [enquiry@growzen.co.in].
14. With regard to security, the Company respects all information provided to it, and takes all reasonable steps towards protection of the same. The Company has implemented technologies with the objective of protecting User’s privacy from unauthorized access and improper use, and periodically review the same. When the User enters sensitive information on Company’s website/application, the Company encrypts the transmission of that information using secure socket layer technology (SSL). The Company maintains procedural safeguards to protect the confidentiality and security of personally identifiable information transmitted to it. The Company takes commercially reasonable technical, administrative and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. The Company cannot guarantee the security of its databases or the databases of the third parties with which it may share such information, nor can it guarantee that the information User supplies will not be intercepted while being transmitted over the internet. In particular, email sent to the Company may not be secure, and the User should therefore take special care in deciding what information to be sent to the Company via email.
15. The Company will permit the providers of information, as and when requested by them, to review the information they had provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient will be corrected or amended as feasible.
16. The Company shall adopt security practices and procedures as prescribed under SPDI Rules such as IS/ISO/IEC 27001 on Information Technology Security Techniques Information Security Management System Requirements, and any other security practices and procedures as mandated by the applicable law from time to time.

D. Information Usage

The Company may use the User Data, for the following purposes:

1. To provide and improve the services provided to the User on the Platform.
2. To improve the content and functionality of the Platform.
3. To open and manage User’s account on the Platform and provide access to different functionalities of the service that is available to him/her as a registered user on the Platform.
4. To resolve disputes and troubleshoot problems.
5. To solicit feedback from the User.
6. To inform him/her about offers, products, services, and any updates on the Platform.
7. To take precautionary measures to protect the Company from any errors, fraud and other criminal or prohibited activity on the Platform.
8. To communicate any notices or changes in the services or use of the Platform or enforce and inform about the terms and conditions to the User.
9. To share any reports periodically or to contact the User via email, telephone calls, short message service, or electronic communication; and
10. Such other purposes as may be specified from time to time.
11. The information collected will be used for the purpose for which it has been collected;
12. The Company will not publish the sensitive personal data or information.

E. Information Sharing

The Company will make reasonable efforts to preserve the confidentiality of User Data and may disclose the User Data in following circumstances:

1. Service Providers, Partners, Vendors & Consultants: In order to effectively carry out the services, the Company may utilize the services of vendors, referrers, advertisers, consultants or any other service providers/partners. The Company may share User Data with such service providers/partners etc. so as to allow them to provide their services.
2. Business transaction: In order to facilitate any business transaction or transfer, the Company may share or transfer User Data in connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition of all or a portion of its business to another company.
3. With affiliates: The Company may share User information with its affiliates in compliance with the applicable laws in order to effectively carry out the services.
4. Compliance with applicable laws and/or required by a governmental or regulatory authority: The User information may be disclosed to the extent necessary: (i) to comply with applicable laws and to respond to lawful requests and legal process, or (ii) to protect the Company’s rights and property or rights and property of any other user, or (iii) to comply with any direction given by any governmental or regulatory authority.
5. Please note that all information shared with the Company’s affiliates or made available to the Company’s affiliates or shared due to any business transaction (as provided above) will be governed by the terms of this Policy. Further, if the User Data is disclosed to third party vendors, consultants and other service providers (as provided above), they shall also be bound by the obligations to keep such User Data confidential and use it only for the purposes for which the Company discloses it to them.
6. Any third party receiving sensitive personal data or information from the Company will not disclose it further.
7. The Company may transfer sensitive personal data or information including any information, to any other body corporate or a person in India, or located in any other country, that ensures the same level of data protection.

F. Storing User Data

The User Data shared with the Company will be protected and preserved by making reasonable efforts at all points of time. The Company will retain User Data as long as is necessary for the purposes of providing the services and for such other purposes as set out in this Policy. After discontinuation of the respective purpose, the corresponding data will be removed in accordance with the applicable laws. The Company will not retain the information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.

G. Disclaimer

The Company makes no representations or warranties, expressed or implied, on products and services offered through the Platform. It accepts no liability for any damages or losses, however, caused in connection with the use of related services. It will not be liable for damages caused by any performance, failure of performance, error, omission, interruption, deletion, defect, delay in transmission or operations, computer virus, communications line failure, and unauthorized access to the personal accounts. It will not be responsible for any technical failure or malfunctioning of the software or delays of any kind. It will also not be responsible for non-receipt of registration details or e-mails. The User shall bear all responsibility of keeping the password secure. The Company will not be responsible for the loss or misuse of the password by any unauthorized person taken from the User.

This Policy does not apply to any personal information collected by the Company other than personal information collected through the Platform and/or for any services provided through the Platform. This Policy shall not apply to any unsolicited information User provides to the Company through the Platform, or through any other means. This includes, but is not limited to, information posted to any public areas of the Platform, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Company shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

This Policy applies only to the Platform. The Platform may contain links to other websites or services not operated or controlled by the Company (the “Third-Party Sites”). The policies and procedures described here do not apply to the Third-Party Sites. The links from the Platform do not imply that the Company endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

H. Changes in the Policy

This Policy is subject to change and may be updated or revised from time to time, without any prior notification to the User, at the sole discretion of the Company. It is User’s responsibility to periodically review the Policy to determine whether there have been any revisions or updates. By visiting and/or using the Platform after the Company makes any such changes to this Policy, the User is deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, Company’s use of the information is governed by this Policy in effect at the time the Company collects such information.

I. Governing Law and Jurisdiction

This Policy shall be governed by, construed and enforced under the laws of India and the courts in Gandhidham / Gujarat shall have exclusive jurisdiction.

J. Clarifications

In case of any information/clarifications required regarding this Policy, the User may contact the Company at [enquiry@growzen.co.in]. For any inquiries or concerns about the handling of your personal information, please contact us on [enquiry@growzen.co.in] or call +91 99786 41009.