Privacy Policy
For the purpose of this Privacy Policy, the “Kapitalize Group”, includes
(i) Accelr8 Distribution Private Limited, ("ADPL") a private limited
company incorporated under the Companies Act, 2013 (CIN U65900DL2022PTC406700); and (ii) includes all
present and future Affiliates of ADPL respectively. The
term “Affiliate” means with respect to an entity, the holding
company, subsidiaries and associate companies and shall include any other entity, individual, firm, or
corporation, directly or indirectly, through one or more intermediaries, controlling, controlled by,
or under common control with such entity.
Accerl8 Distribution Private Limited and/or its
affiliates ( “Kapitalize”/ “Company”/ “We”/
“Our”/ “Us” ) may become privy to some Personal Information (
defined below ) provided by individuals ( “Users”/
“You”/”Your” ), including information which may or may not be of
confidential nature. We value Your privacy and recognises the importance of maintaining the privacy of
Your Personal Information and appreciate Your trust in Us.
For all intents and purposes of this
Privacy Policy ( “Policy” ), Personal Information shall mean any
information provided by You and/or available with the Company, which helps the Company identify You.
However, no such information which is already available in public domain, or which can be furnished
under Right to Information Act, 2005 or any law in force in India shall be considered as Personal
Information under this Policy ( “Personal Information”
).
This Policy will help You understand the types of information we collect from You through
Promotional Material (defined below) and/or the website, https://www.kapitalize.in (hereinafter referred as
“Platform” ), which are owned, operated and maintained by Kapitalize; the purpose
for which the information is collected; how the information is used; the intended recipients of such
information; and how the information is protected. If You would like more details, please contact Us
at service@kapitalize.in
By accessing /
browsing the Platform; or providing information on the Platform or through any of the Promotional
Material; or signing up for the Services ( as defined under the Terms of Use ) offered by Kapitalize; or providing Us
with Your Personal Information for any other purpose, You agree to the terms of this Policy and give
consent to the Company to collect such information including Personal Information provided by You as
per the Policy. This Policy is incorporated into and subject to the Terms of Use (“Terms”) of the Platform and
shall be read harmoniously and in conjunction with the Terms. This Policy applies to all the
information including Personal Information collected by Us.
1. Collection of
Information
I. Information You voluntarily submit
We collect
Personal Information from You when You voluntarily provide such information, such as when You contact
Us with inquiries, register for access to the Platform or purchase products or Services from the
Platform.
a. Using Kapitalize Platform as a Visitor
Every time You
visit / access / use Our Platform, We collect certain information about Your interaction with Our
Platform, such as pages visited and average time spent on the Platform, Your internet protocol
address, the unique identifier of Your device and device information such as operating system,
operating system version, browser plugins, cache, system activity, hardware settings, date and time of
Your request and referral URL, and cookies that may uniquely identify Your browser, browser data,
mobile application and mobile information.
b. Interaction with Kapitalize’s
Promotional Material
We collect information which You may provide while interacting
with Our promotional material which includes but not limited to promotional emails, newsletters and
advertising material ( “Promotional Material” ). This information
includes the number of clicks, time spent viewing the links from the Promotional Materials, Your
Personal Information, etc.
c. Using Kapitalize as a Registered User
If
You have applied for an invite:
i. To complete your profile assessment We may ask You questions
(quiz) related to Your investment report, age of investing, Your risk appetite for investments, Your
age and investment goals.
ii. We shall collect Your Personal Information such as first name,
last name, company name, current contact and address details, email address, designation, password,
date of birth, signature, PAN, place of birth, city, country, complete address, pin code along with
information regarding whether you are Politically Exposed Person (PEP), your annual income/net worth,
billing information, and ask to access Your LinkedIn profile link, Facebook link, Twitter link and
Google account.
iii. We may also ask for additional information in order to use certain
features of the Services.
iv. We also collect technical data about Your interaction with the
Services. The technical data includes but is not limited to Your internet protocol address, the unique
identifier of Your device and device information such as operating system, operating system version,
browser plugins, cache, system activity, hardware settings, date and time of Your request and referral
URL, and cookies that may uniquely identify Your browser, browser data, mobile application and mobile
device information.
v. We also collect Your IP address.
Our legal basis for processing
this information is Your consent, and by voluntarily providing Us with Personal Information, You are
consenting to Our use of it in accordance with this Policy. If you provide Personal Information to Us,
You acknowledge and agree that such Personal Information may be transferred and stored from Your
current location to the offices and servers of Kapitalize and the authorized third-parties referenced
below.
Kapitalize shall not be liable for the authenticity/misrepresentation/fraud/negligence
for the information provided by You. The Company shall also not be responsible for verifying any
information provided by You. The sole liability for any misrepresentation/fraud/negligence/ any other
criminal or civil liability emanating from the information provided by You shall be Your
responsibility.
II. Information We Collect from Others:
We may receive
information about You from other sources such as when You use a third-party software through the
Platform, they may transfer information to Us for fulfilment of their obligations under agreement
between such third-party and Us. For more information about our use of third-party providers, please
see further below.
III. Information We Collect within the Kapitalize
Group:
We may receive information about You from an entity in the Kapitalize Group
when You use the Services offered by such entity through the Platform. Such entity within the
Kapitalize Group may transfer the information to Us for providing relevant Services and for fulfilment
of their obligations under agreement, if any, between the entities within the Kapitalize
Group.
IV. Automatically-Collected Information:
We automatically
collect certain information about You and the device with which You access the Platform such as Your
IP address, operating system type, browser type, referring website, pages You viewed, mobile
application, mobile device information and the dates/times when You accessed the Platform. We may also
collect information about actions You take when using the Platform, such as links
clicked.
V. Cookies:
We may log information using cookies, which are
small data files stored on your browser by Kapitalize. We may use both session cookies, which expire
when you close your browser, and persistent cookies, which stay on Your browser until deleted, to
provide You with a more personalized experience on the Platform.
2. Use of Your
Information
We use all the collected data to:
a. respond to Your queries
about the Services;
b. send communications relevant to Your use of the Services;
c.
offer You products or Services that We believe may be of interest to You;
d. tailor Your
experience at the Platform, providing You with content that We think You might be interested in and to
display content according to Your preferences;
e. to send You Promotional Material, however, We
will provide You the ability to opt-out of receiving such emails from Us. If You opt out, the Company
may still send You non-promotional emails, such as emails about the Services, Your account on the
Platform and information on the use of the Platform;
f. ensure security on the Platform and
detect any errors, fraud and other criminal or otherwise prohibited activity on the
Platform;
g. aggregate the anonymised information from registered Users to perform market
research, project planning, product development, troubleshoot problems, analyse User behaviour,
marketing purposes, and promotions;
h. identify and use Your IP address to help diagnose
problems with Our server, resolve such problems and administer the Platform. Your IP address may also
be used to help Us identify You and to gather broad demographic information;
i. be compliant
with Foreign Account Tax Compliant Act (FATCA) and other applicable laws;
j. enforce Our Terms
of Use; and
k. use Your information to verify Your identity in the event You contact Us for
assistance of Our Services. We use cloud-based software tools to perform certain business-related
functions. Examples of such functions include, maintaining databases and servers, processing text
messages, phone calls, chats and emails, and marketing and sales analytics.
3.
Connecting Your email/LinkedIn account
Kapitalize will seek Your consent to
connect/integrate Your email account(s)/LinkedIn account/Facebook account/Twitter account/Google
account with Your account on the Platform by clicking on the authentication email sent by Us on Your
registered email address or by seeking permission on Your LinkedIn account/Facebook account/Twitter
account/Google account. We request You to review the information prior to giving Your consent for
integration of the email addresses/LinkedIn account/Facebook account/Twitter account/Google account
with the account on the Platform.
Once connected, the Platform will securely access and curate
specific financial/investment/ other products and Services for You based on Your Financial
transactions, investments and past financial behaviour. You may at any time opt to de-link Your email
addresses and LinkedIn account connected with the account on the Platform, by managing these
connections with the options provided on the Platform. Such de-linking can also be achieved by
reviewing permissions on the email account or linked-in account.
4. Links to Other
Third – Party platforms and collection of information
Kapitalize may link You
to other third-party platform that may collect Your Personal Information such as Your IP address,
browser specification, or operating system.
Kapitalize does not take responsibility for the
security of such information or their privacy practices or content of those third-party platforms.
Additionally, You may also encounter “cookies” or other similar devices on certain pages
of the third-party platform and We clarify that the Kapitalize Platform does not control the use of
cookies by these third-party platforms. These third-party service providers may have their own privacy
policies governing the storage and retention of Your information that You may be subject to. This
Policy does not govern any information provided to, stored on, or used by these third-party providers.
You are advised to review the privacy policy of these third-party Platform.
5. How We
Use Technical Data
Kapitalize uses third-party web analytics service providers such
as Google Analytics, Clevertap, Hotjar and Clearbit. These web analytics services aggregate Personal
Information, geographical data and other cookies based data. We use this information to identify the
most popular areas of the Services and how to best present and customise them. We may use the unique
identifier of Your device for security purposes to track suspicious activity. For instance, if We
detect that Your Kapitalize account is being accessed from multiple devices, We may contact You to
ensure that You have authorised such access. You consent to process the information provided by You
including Personal Information through third party web analytics service providers in accordance with
this Policy.
6. Access and Update Your Personal Information
If You want
to review your Personal Information or believe that the Personal Information provided by You on the
Platform or through Promotional Material is inaccurate or not up to date or have any questions about
the accuracy or safety of Your Personal Information, please do contact Us
at service@kapitalize.in.
7. Disclosure of
Information
Except as provided in this Policy, Kapitalize will not transfer, sell or
rent Personal Information collected to anyone, for any reason, at any time. Kapitalize shall also
ensure reasonable care and prevention of any unauthorised disclosure of Your sensitive Personal
Information. Kapitalize will share Your information with judicial, administrative and regulatory
entities to comply with any legal and regulatory requirements under applicable laws.
8.
Payment Information:
You may provide payment information when You use the Platform
to avail Our Services such as debit card numbers, billing information using third-party intermediary
PCI-DSS compliant service providers. The payment information is provided directly by You, via the
Platform, into the PCI/DSS-compliant payment processing service to which Kapitalize subscribes, and
Kapitalize does not, itself, process or store the payment information. Further, these intermediaries
are not permitted to store, retain, or use Your billing information for any purpose except for payment
processing on Our behalf.
9. Retention of Personal
Information
Kapitalize will keep Your Personal Information as long it is required
for the purpose for which it has been collected including to make available the Platform and provide
Our Services or for other legitimate purposes, such as complying with legal obligations, enforcing and
preventing violations of our Terms of Use, or protecting or defending our rights, property and users.
The storage periods are determined on a case-by-case basis that depends on factors like the nature of
the information, why it is collected and processed, relevant legal or operational retention needs, and
legal obligations. Kapitalize will make sure to delete any Personal Information collected and stored
by it once the purpose has been fulfilled or the Personal Information is no longer needed by
Kapitalize.
10. Personal Information of Minors
Kapitalize may collect
and/or store Personal Information of persons under the age of 18 years
( "Minors" ) that their parent or guardian under applicable laws,
provide on the Platform to avail the Services. While providing Personal Information of the any Minor,
the parent or guardian under applicable law, gives consent to Kapitalize, to store / use such Personal
Information of Minors as per the Policy.
11. Customer Care
If You have
any complaints or queries regarding Your Personal Information or the Policy, please
contact:
Name – Laksshey Khanna
Email - service@kapitalize.in
12.
Deletion
In the event that Your Personal Information is deleted from Our servers due
to application of law, withdrawal of Your consent or due to any other reason, You agree that You will
not access any or all Our Platforms or Services.
13. Security Practices and
Procedures
Our Platform has stringent security measures in place to protect the
loss, misuse, and alteration of the information under Our control. Whenever You as a Registered User
change or access Your account information, We offer the use of a secure server. Once your information
is in Our possession We adhere to strict security guidelines, protecting it against unauthorized
access. We are in compliance with privacy laws of India and are not bound by privacy laws of any
jurisdiction other than India.
Kapitalize follows industry best practices, using open and known
principles when transferring and storing Your data. All the User data is stored securely on Amazon Web
services (AWS) cloud. However, Kapitalize cannot guarantee absolute security as no security measure
can provide 100% security of the information transmitted on internet or electronically stored on
servers.
We also train and require Our employees to safeguard Your information. We also use
physical, electronic and procedural safeguards and provide access to Personal Information only to
employees, agents and/ or Affiliates on a need to know basis.
We assume no liability for any
disclosure of information due to errors in transmission, unauthorised third-party access to Our
Platform and data bases or other acts of third-parties, or acts or omissions beyond Our reasonable
control and You shall not be entitled to hold Kapitalize responsible for any breach of security. In
the event Kapitalize becomes aware of any security breach, it will notify You as soon as possible and
take appropriate action to the best of its ability to remedy such a breach.
If You think that
the security of Your Kapitalize account has been compromised, You shall change Your password and
contact Us immediately for further assistance.
14. Use of Google API server
data
Kapitalize’s use of information received from Google APIs will adhere
to Google API
Services User Data Policy, including the Limited Use requirements.
15. How Your
Information is Transmitted and Stored
Your information including Personal
Information is transmitted between Your device and Our servers using HTTPS protocol for encryption.
HTTPS is the technology used to create secure connections for Your web browser and is indicated by a
padlock icon in Your browser. In addition to HTTPS, We make sure that Your Personal Information is
always encrypted or hashed before We store it. We use industry standard encryption and hashing
algorithms.
16. Consent Withdrawal
If You wish to withdraw Your consent
given under this Policy for collection and use of any Personal Information, You can withdraw Your
consent by sending Us an email at service@kapitalize.in.
17. Grievance
Officer
In accordance with Information Technology Act 2000 and rules made there
under, the name and contact details of the Grievance Officer are provided below:
Mr. Laksshey
Khanna
Email: service@kapitalize.in
18. Legal Obligation and
Jurisdiction
Kapitalize is bound by the (Indian) Information Technology Act, 2000
and rules made thereunder, and it shall comply with all its provisions. Under Section 43A of the
(Indian) Information Technology Act, 2000, Kapitalize and all its vendors are obliged to maintain
reasonable security procedures to safeguard Your data.
Any disputes arising under this Policy
shall be governed by the laws of India.
19. Updates to this Policy
This
Policy was last updated on January 26, 2023 ("Last Update Date"). From time to time We may
change Our Policy. We will notify You of any material changes to this Policy as required by law. We
will also post an updated copy of the Policy on Our Platform. Please check Our Platform periodically
for updates on the Policy. Changes to this Policy will be effective as of the stated Last Update Date
mentioned in the Policy. By continuing using the Platform i.e. by providing information on the
Platform / browse the Platform / access the Platform / use the Services provided by the Company on the
Platform, after any change in this Policy, You agree with the modified and updated Policy and provide
consent to the collection of information including Personal Information disclosed by You on the
Platform according to terms of such modified Policy.