Privacy Policy
This privacy policy document (“Privacy Policy”) is published in accordance with the provisions of Rule 4 (1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information.
- General
1.1 Amica Investment Advisors Private Limited is a company incorporated under the Companies Act, 2013 (CIN: U65929MH2019PTC335288), and registered with the Association of Mutual funds of India as a Category-1 Execution only Platform vide registration no.0005 and having its registered office at 31, Viraj, Plot No. 124, Above HDFC Bank, SV Road, Khar-West, 400052, offering Mutual Fund Schemes on behalf of Mutual Fund Companies (“EOP”) which allows users to invest in, track and manage their investments in direct plans of mutual fund schemes (“Services”), through the Mutual Fund Investment Platform (“Investment Platform”) on the mobile application of Amica Financial Technologies Private Limited (“Jupiter App”). From time to time, the Investment Platform may allow users to invest in other investment products.
1.2 For the purpose of this Privacy Policy, wherever the context so requires, ‘You’ or ‘Your’ or ‘User’ shall mean any natural person who has already signed up on the Jupiter App and intends to access the Investment Platform and/or avail the Services offered on the Investment Platform. Further, wherever the context so requires, ‘We’, ‘Us’ or ‘Company’ shall mean Amica Investment Advisers Private Limited.
1.3 This Privacy Policy provides specific information on who is processing Your data, how and why it is being processed and Your rights with regard to the control over Your data when availing of the Services offered on the Investment Platform.
1.4. Please read the terms of this Privacy Policy carefully before accepting. By accepting the terms of the Privacy Policy, You agree that You have read, understood, acknowledged and accepted this Privacy Policy to access and use the Investment Platform. By directly or indirectly using the Investment Platform, and/or having availed the Services offered on the Investment Platform, in the past, present or future, You explicitly consent to the collection/sharing/processing/use/
storage/disclosure of Your Personal Information and Non-Personal Information by Us and our associate/affiliate companies/Partner Bank (Federal Bank) /Asset Management Companies/ relevant AMCs for providing the Services to You in compliance with this Privacy Policy. We reserve the right to update the terms of the Privacy Policy from time to time. Please ensure that You read the terms of the Privacy Policy periodically to stay updated on the latest version of the Privacy Policy. If You do not accept the terms of the Privacy Policy, the terms and conditions of use (“Terms”) and the Disclaimer Document, You must not access or use the Investment Platform. - Types of Data that we may collect from You
2.1 We and our associate/affiliate companies/Partner Bank (Federal Bank)/Asset Management Companies/ relevant AMCs need to collect/receive/share/process/use/store Your information to the extent required to provide the Services, enhance the user experience, build affluence scores/ user insights, analyse data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations. We may collect/receive/share/process/use/store the following information about You as well as the device from which you avail of the Services.
2.2 “Personal Information” will inter alia include any information which is directly or indirectly available with Us to identify or verify individual identity. This may also include sensitive personal data which inter alia includes financial information such as bank account, debit card details, biometric information.
2.3 “Non-Personal Information” may be collected by Us which cannot be used to identify an individual, while he/she uses the Investment Platform. This information inter alia includes IP address, browser type, name of the individual’s internet service provider.
Categories of data/ information which We and our associate/affiliate companies/Partner Bank (Federal Bank) may collect/receive/share/process/use
/store in order to serve You through the Investment Platform:
|
Categories of Data |
Information Processed |
|
Personal Particulars |
Full name, title, age, user ID, gender and date of birth (DOB). |
|
Contact Information |
Telephone/mobile number(s), permanent, current and shipping address, state/city of residence, country, pin code, email address. |
|
Financial Information |
Details of Your active bank account opened on the Jupiter App (“Partner Bank Account”) including account number, Partner Bank customer ID, e-nach, NEFT, IMPS and UPI ID details, debit card information, including the debit card number, card type, expiry date on the debit card, and name on the card, salary and income details. |
|
Identification Information |
Know Your Customer (KYC) documents including all proofs of identity and address, photograph, Permanent Account Number (PAN), signature, email ID, occupational details, etc. |
|
Transactional Information (Money Flow) |
UPI ID, category and other identifiers along with the details of Services availed on the Investment Platform, mode of payment, location, the date, currency and amount of the transaction, whether the payment was successful, and other information provided by You directly or indirectly to Us or provided to Us by other third party entities. We also store transaction details such as amount spent, counterparty details, beneficiary information, account balance, transaction ID, date and time of transaction. Further, we may store information relating to your income, lifestyle levels and usage pattern. |
|
Usage and Technical Information |
IP addresses, application, device or browser type, versions and configurations, operating systems, device brand and model, time zone setting, geo-location information, content, unique identifiers associated with Your device(s) and pages that You access on the Investment Platform and the dates and times that You visit the Investment Platform, and paths taken. |
|
Investment Information |
Information about Your investments. |
|
Marketing and Communication Information |
Communications with customer service support, behavioural data (for example, data collected using cookies), information about promotions, surveys, promotional campaigns and records of Your decision(s) to subscribe or to withdraw from receiving marketing materials, if any. |
|
Information in you device(s) |
We may also access Your contact list, call records, SMS, camera, media files and location data in your devices for various purposes after seeking necessary permissions. |
2.4 You hereby agree, acknowledge and grant your consent to Us to obtain information/data from You through the Investment Platform, the Jupiter App, different communication channels, when You provide Your details in forms, surveys, online applications or similar online fields. Further, You hereby agree, acknowledge and grant your consent to allow Us to obtain/share Your information/data from/to third-party entities including but not limited to our associate/affiliate companies/Partner Bank (Federal Bank), relevant AMCs, RTAs, KRAs, business partners and financial institutions, to the extent required to provide the Services, enhance the user experience, build affluence scores/ user insights, analyse data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations.
3. Purpose and Use of Your Data
3.1 We recognise and acknowledge the value and importance of the protection of Your Personal and Non-Personal Information and ensure that the same will be used for the intended purpose(s). By virtue of this Privacy Policy, We will collect/receive/share/process/use/store Your Personal Information and/or Non-Personal Information in accordance with applicable laws to provide You with the Services, enhance the user experience, manage our relationship with You, build affluence scores/ user insights, analyse data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations, which may inter alia include:
3.1.1 Facilitating various services provided by Us, including:
i. Setting up Your designated investment account and facilitating the processing of Your investment/redemption instructions which You may initiate through the Investment Platform via Your designated investment account (“Transaction Instructions”).
ii. Maintaining a record of Your Transaction Instructions, transactions and holdings, generating and sending reminders, alerts, notifications to You for transactions, upcoming funds transfers, etc.
3.1.2 Verifying Your identity for the purposes of allowing You to avail of the Services on the Investment Platform.
3.1.3 Checking/updating/registering Your KYC details in centralized KYC databases.
3.1.4 Resolving Your queries, concerns and providing You with support in the case of any issues during the use of the Services.
3.1.5 Informing You about any offers relating to our Services including sharing of marketing material with You.
3.1.6 Streamlining and customizing Your experience of using the Investment Platform.
3.1.7 Informing You about the progress of and issues with, if any, pertaining to the Transactions Instructions initiated by You and the resolution thereof or relating to the services availed by You.
3.1.8 Facilitate the transfer of funds between Your Partner Bank Account and the bank account(s) of the concerned AMCs vide partnered bank and 3rd Party Service Provider.
3.1.9 Tracking, analyzing and maintaining information about Your use of the Investment Platform.
3.1.10 Carrying out research, planning and statistical analysis.
3.1.11. Undertaking analytics for the purposes of developing or improving our products, services, security, service quality, and advertising strategies.
3.1.12 Managing our infrastructure and business operations and complying with
internal policies and procedures.
3.1.13 Conducting credit checks, screenings or due diligence checks as may be
required under applicable laws, regulations or directives.
3.1.14 Complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities.
3.1.15. Undertaking financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record-keeping activities.
3.1.16 Enforcing obligations owed to Us.
3.1.17 Communicating with our associate/affiliate companies/Partner Bank (Federal Bank) with respect to their products/services that You may have availed through Us.
3.1.18 Enabling our associate/affiliate companies/Partner Bank (Federal Bank) to communicate with You with respect to their products/services that you may have availed through Us.
3.1.19 Using Your information in other ways as required or permitted by law or with Your consent.
3.1.20 The data collected by cookies helps Us track, analyse and understand Your trends so as to enable Us to understand lacunas (such as slow response time on the Jupiter App) and improve Your interactive experience of using our Services, our design, features and functionalities.
3.2 You understand, acknowledge and expressly grant Us Your consent:
3.2.1 To share/receive your Personal Information and/or Non-Personal Information with/from our associate/affiliate companies/Partner Bank (Federal Bank), relevant AMCs for the purposes which are not limited to providing You with the Services, improving the existing Services, enhancing the user experience, building affluence scores/ user insights, outsourcing relationship management activities, analysing data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations.
3.2.2 To share Your Personal Information and Non-Personal Information with the companies that We plan to merge with or entities that We may acquire or be acquired by subject to the provisions of applicable law, in which situation We will require that the new combined entity or the acquired/ acquiring entity follows this Privacy Policy with respect to Your Personal Information.
3.2.3 To collect/receive/process/use/store certain Personal Information (including PAN, DOB, residential status, etc.) that You may have shared with Amica Financial Technologies Private Limited in order to allow Us to provide the Services to You. Further, You expressly consent that certain Personal Information that may be shared by You with Us, including financial information (such as debit card details or other payment mode details), or Your information that may be collated by Us from the KRAs/ relevant AMCs may be shared with Amica Financial Technologies Private Limited in order to facilitate the provision of our Services to You.
4. Links to Other Sites
4.1 Links to third-party advertisements, third-party websites/ applications/ products/ services or any third-party electronic communication service (“Other Websites”) may be provided on the Investment Platform which are operated by third-party entities and are not controlled by, or affiliated to, or associated with Us unless expressly specified on the Investment Platform.
4.2 We are not responsible for any form of transmission, whatsoever, received by You from any third party website. Accordingly, We do not make any representations concerning the privacy practices or policies of such third party entities or terms of use of such Other Websites, nor do We control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such Other Websites. The inclusion or exclusion does not imply any endorsement by Us of the Other Websites, the website's provider, or the information on such Other Websites. The information provided by You to such Other Websites shall be governed in accordance with the privacy policies of such Other Websites, and it is recommended that You review the privacy policy of such Other Websites prior to using such websites.
5. Data Retention
5.1 Notwithstanding anything to the contrary mentioned elsewhere in the Privacy Policy, We may store/retain Your Personal and Non-Personal Information for as long as the same is required for the fulfilment of purposes for which We collected it. The retention of Your Personal Information and/or Non-Personal Information by Us is determined by considering compliance with legal (contractual, statutory or regulatory requirements), accounting and compliance reporting requirements. Retention of Your Personal Information and/or Non-Personal Information will also be applicable pursuant to cancellation/ deactivation/ non-subscription of Your designated investment account with Us.
6. Your Rights
6.1 We seek to provide reasonable assistance to cater to request(s) from You regarding the processing of Your Personal Information and the right to amend and withdraw permission to the processing/use/storing/sharing of Your Personal Information. In accordance with applicable laws and as per the terms of this Privacy Policy, You may exercise the following rights:
6.1.1 Access the information We hold about You, or get a copy of it in a portable (machine-readable) format or request Us to send it to a third party.
6.1.2 Review, correct or rectify the inaccurate Personal Information stored with Us.
6.1.3 Withdraw Your consent to collect/receive/share/process/use/store Your Personal Information that You had given Us for availing the Services and prevent further processing of Your Personal Information subject to the terms of this Privacy Policy. You may also withhold Your consent prior to the collection and processing of Your Personal Information and Non-Personal Information.
6.1.4 Ask Us to delete Your Personal Information. However, You understand that the deletion of certain information may impact the Services being offered to You and the same may result in total suspension of the Services if the deleted information is of a category that is considered mandatory to provide the Services.
You can exercise any of the aforementioned rights by submitting a request to compliance_mf@jupiter.money
6.2 You understand that these rights are limited in some situations, such as, where We are legally or otherwise bound to process/retain/share/disclose Your Personal Information. This may also affect our ability to provide You Services and therefore may lead to discontinuation of the Services You avail from the Investment Platform.
7. Security Precautions
7.1 We work to protect the security of Your Personal Information during transmission by using appropriate software, which encrypts information You input. This encrypted information is stored on secure servers and data centres. Further, We ensure that the number of employees involved in the management of the data centre who have physical access to these computers is limited. Also, We use advanced security technology to prevent our computers from being accessed by unauthorized persons.
7.2 We have also implemented information security practices and standards and have in place information security programmes and policies containing managerial, technical, operational and physical security measures that are in compliance with the applicable laws including, so as to protect the information provided to Us from unauthorized access, use, modification, damage, disclosure or impairment. Further, We may from time to time use reasonable additional or alternative procedures to ensure the security and confidentiality of Your Personal Information through our Investment Platform.
7.3 No data transmission over the internet is fully secure, so We cannot ensure or warrant the security of any information You submit to us. Further, We do not guarantee in any way, the security of any information that You transmit or share on the Investment Platform; and You do so at Your own risk.
8. Disclaimer of Information
You are responsible for maintaining the accuracy, truthfulness, correctness and completeness of the Personal Information You provide Us and our associate/affiliate companies/Partner Bank (Federal Bank), relevant AMCs that is necessary for providing the Services to You. You shall hold harmless and indemnify Us and our associate/affiliate companies from and against all claims arising out of or in relation to the wrongful Personal Information provided by You to Us and our associate/affiliate companies/Partner Bank (Federal Bank) and relevant AMCs. If your Personal Information changes, You shall correct, delete inaccuracies, or amend Your information by making the necessary change on the information on the Investment Platform/Jupiter App or contact us at compliance_mf_eop@jupiter.money
9. Changes to Privacy Policy
9.1 We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, We shall update the same on the Jupiter App and Investment Platform. Please revisit the Jupiter App and Investment Platform periodically for the latest information on our privacy practices. Once posted, those changes are effective immediately unless stated otherwise. Continued access or use of the Investment Platform or availing of the Services constitutes Your acceptance of the changes to the amended Privacy Policy. However, if You do not agree with the changes, please do not continue to use the Investment Platforms or avail of the Services or submit Your Personal Information to Us and notify Us about Your disagreement over an email. Subsequently, upon confirmation from the Company, Your access to the Investment Platform will be suspended.
10. Contacting Us
10.1 In accordance with Information Technology Act 2000 and rules made thereunder, the name and contact details of the Grievance Officer are provided below for your reference:
Mr. Vivek Agarwal
Aminca Investment Advisors Private Limited
Email: compliance_mf_eop@jupiter.money
