Jupiter Privacy Policy

AMICA FINANCIAL TECHNOLOGIES PRIVATE LIMITED
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

AMICA Financial Technologies Private Limited (the “Company” or “Jupiter” or “we” or “our” or “us”) is a company incorporated under the Companies Act 2013, bearing CIN No. U74140MH2019PTC328769. Jupiter provides various banking and non-banking services in association with the Banks, Non-Banking Financial Company (NBFC) and our partner establishments through its mobile application Jupiter (“App”) and website www.jupiter.money (“Website”) (App and Website hereinafter together referred to as the “Jupiter Platform”).

For the purpose of this Privacy Policy, wherever the context so mentions "user" or "you" or "your”, it shall mean any natural or legal person who has visited Jupiter App, Website or Platform and/or has agreed to or has enquired open an account and/or initiated the process of opening an account with Jupiter.

Access to your Jupiter account and the usage of your account is subject to your compliance with all the terms and conditions set forth herein, read along with all documents, including but not limited to; applications forms and undertakings, signed by you during account opening, and any terms/consents/policies included on Jupiter’s App and Website or Platform including Terms and Conditions available at Website-. Capitalized words not defined herein can be referred to in Terms and Conditions.

This Privacy Policy provides specific information on who is processing your data, how and why it is being processed and your rights with regards to the control of your data when availing the Services through Jupiter Platform.

The term Website includes all pages that are sub-domains or are associated with or exist within each Website which are hosted by Jupiter. By accessing the Jupiter Platform and/or using products or Services provided by Jupiter directly or indirectly, you agree that you have read and understood, and agree to be bound by this Jupiter Privacy Policy. By using the Jupiter Platform, and/or having used the products or Services offered by Jupiter directly or indirectly, in the past, present or future, you expressly consent to our use and disclosure of your Personal Information and Non-Personal Information submitted to us in accordance with this Privacy Policy. You further acknowledge and accept that your consent herein shall also be applicable to your Personal Information and Non-Personal Information submitted to us, directly or indirectly, in the past.

It is strongly recommended for you to return to this page periodically to review the most current version of this Jupiter Privacy Policy which is amended by us from time to time.

If you do not agree to this Privacy Policy or any part thereof, please do notuse/access/download/install/sign-up to the Jupiter Platform. Kindly refer to ‘CHANGES TO PRIVACY POLICY’ clause herein.

TYPE OF DATA WHICH WE COLLECT FROM YOU

“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, credit and debit card details, biometric information.

“Non-Personal Information” may be collected by Jupiter which cannot be used to identify individual, while you are using Jupiter Platform. This information inter alia includes IP address, browser type, name of your internet service provider

(Personal Information and Non-Personal Information hereinafter together referred to as the “combined information”).

Categories of data/ information which we may process in order to serve you according to the service or product you opt for through Jupiter Platform:
Categories of Data Information Processed
Identity and Account Opening Information Full name(s), title, age, user ID, gender and date of birth
Contact Information Telephone/mobile number(s), permanent, current and shipping address, state/city of residence, country, pin code, email address
Financial Information Personal and Partner Bank account numbers and bank account data including e-nach, NEFT, IMPS and UPI ID details, credit or debit card information, including the credit or debit card number, card type, expiry date on the credit or debit card of other banks, and name on the card, salary and income details, loan account details
Identification Information Know Your Customer (KYC) documents including all proofs of identity and address, photograph, Permanent Account Number (PAN), signature, Partner Bank Customer ID, employer name, corporate email ID, etc.
Transactional Information (Money Flow) UPI ID, details from payment system providers, TPAPs,, name of issuing bank, merchant’s name, category and other identifiers along with the details of products or services purchased or paid for, 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 banks, merchants or other service providers or business partners.
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 Website(s), Apps or Platforms, and the dates and times that you visit the Website, App or Platform, and paths taken.
Credit and Lending Information Credit or affluence related information or assessment, credit information report, credit or affluence score or reliability scores provided by third parties such as financial institutions or credit information companies or account aggregators or similar third parties as permitted under applicable laws of India including our business partners, independent service providers and our group entities.
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 your 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.
We process/collect data received (a) directly from you through Jupiter Platforms or through different communication channels or the services or product you entail to use and when you provide your details in forms, surveys, online applications or similar online fields (b) indirectly from third party sources including but not limited to credit institution companies, NSDL (for PAN), market research, publicly available information, payment gateway companies, business partners, financial institutions.

All these data are processed in regard to providing you better services and product,managing our relationship with you, fulfilment of contractual and regulatory obligations.

During the account opening process on Jupiter Platform, you do not share aadhaar number with Jupiter. You would be redirected to the Partner Bank platform for completing your aadhaar verification.

GOOGLE API SERVICES

You can choose to provide explicit consent to connect your Google account with your Jupiter App account to experience seamless integration with our portfolio analyzer service. This will provide us “read only” access to your Gmail content and attachments from a set of white-listed senders and/or emails that match the prespecified search query as mentioned below.

Connecting your Google account with the App is completely optional and based on your explicit consent for only specific use cases as has been described in this Privacy Policy.

You can choose to enable our access to your one or more Google accounts with your Jupiter App account.

We may run the following search query on your Gmail account to identify and access emails and their attachments that contain the data required for processing your request:

subject:"Consolidated Account Statement - CAMS Mailback Request" orsubject:"Consolidated Account Statement - KFINTECH Mailback Request", newer_than:7d

The white-listed senders specifically comprise of:
If the sender email IDs or the search query is changed, then we will update it in the Privacy Policy.

The emails and attachments identified will contain the details of your investments such as folio numbers, transaction dates, dividends, subscription and redemption amount, etc.

Jupiter uses the collected data for the following purposes:
  • To provide in-depth analysis of your mutual fund investments across different asset management companies in the form of a report that will be available on the App and sent to you as an email.
  • Use aggregated data for internal operations and improving analytics
Your report will be auto-updated every month or after a predetermined period or when you explicitly request a refreshed report, so that it reflects the latest changes you have made to your investments.

You can choose to de-link your Google account with your Jupiter App account at any time by writing to support@jupiter.money

Alternatively, you can also de-link your Google account by visiting your Google Mail’s permission settings located at: myaccount.google.com/permissions

The email content and/or attachment may be shared securely with Jupiter’s business partners and third parties for the purpose of parsing the data accurately.

We only transfer the data to others if necessary to provide or improve user-facing features that are prominent in the requesting application's user interface.

Jupiter’s use of information collected from Google API will adhere to Google API Services User Data Policy , including the Limited use requirements.

This act of connecting your Google account with Jupiter account comes under the“Restricted Scopes” under Google API Services User Data Policy.

Jupiter ensures that it is always in compliance with the restricted scope defined under Google OAuth API policies.

We do not use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising.

We don't allow humans to read the data, unless :
  • We first obtain your affirmative agreement for specific messages
  • It is necessary for security purposes (such as investigating a bug or abuse);
  • It is necessary to comply with applicable law; or
  • Our use is limited to internal operations and the data (including derivations)have been aggregated and anonymized.
These prohibitions of use of data apply to the raw data obtained from Restricted Scopes and data aggregated, anonymized, or derived from them. Our employees, agents, contractors, and successors comply with the “Google API Services: User Data Policy”

PURPOSE AND USE OF YOUR DATA

We understand the importance of your Personal and Non-Personal Information and ensure that it is used for the intended purpose only. We access, store and use the combined information we collect from you in accordance with the applicable laws to provide our Services, to research and develop new ones subject to the limitations set out in this Privacy Policy.

We require the profiling information which includes details such as identity details, contact details, usernames and passwords in order to manage our relationship with you and provide services to you. This information is used for specific business purposes or for other related purposes designated by Jupiter or for a lawful purpose to comply with the applicable laws and regulatory and contractual obligations which inter alia includes:

  1. developing and providing banking or non-banking facilities, products or services (whether made available by us or through us), including but not limited to executing investments, banking, commercial or other transactions and clearing or reporting on these transactions;
  2. carrying out research, planning and statistical analysis;
  3. analytics for the purposes of developing or improving our products, services,security, service quality, and advertising strategies;
  4. assessing and processing applications, instructions or requests from you;
  5. communicating with you, including providing you with updates on changes toproducts, services and banking facilities (whether made available by us or throughour business partners) including any additions, expansions, suspensions andreplacements of or to such products, services and banking facilities and their termsand conditions;
  6. managing our infrastructure and business operations and complying with internal policies and procedures;
  7. responding to your queries or feedback;
  8. addressing or investigating any complaints, claims or disputes;
  9. verifying your identity for the purposes of providing banking facilities, products or services;
  10. conducting credit checks, screenings or due diligence checks as may be requiredunder applicable law, regulation or directive or under contractual arrangement with Partner Bank and Non-Banking Financial Company;
  11. to prevent or detect crime including fraud and financial crime, e.g. financing for terrorism;
  12. financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
  13. To enter into a contract with you or to take steps pursuant to your request prior to entering into a contract.
  14. to use it in other ways as required or permitted by law or with your consent;
  15. 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 our website page or application) and improve your interactive experience of using our Services, our design, features and functionalities.
You expressly consent to share your Personal Information with our business partners, third party, collection agencies, Partner Banks with whom we have contractual arrangement for the purpose which are not limited to improving existing Services, data enrichment, generate affluence score, outsourcing relationship management activity, collection of overdue, launch of ancillary service or product.

We may share your combined 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 Jupiter’s Privacy Policy with respect to your Personal Information.

We may share your Personal Information when required by law enforcement, regulatory bodies, government officials, fraud detection agencies, financial institutions or other third parties as and when we are compelled to do so under applicable laws, courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunal. You understand that we may share your Personal Information with international entities we partner with for the offer and/or development of products and services subject to the requirements under this Jupiter Privacy Policy and applicable laws. Jupiter ensures that every third party that is involved in the processing of your Personal Information under acontract with us has the required organizational and technical protections in place as may be required in accordance with applicable laws in India.

You further understand that we may use your combined information that is collected by us to market our product and Services including product and services of our business partners, independent service providers and/or our group entities and affiliates and to notify you about offers, sponsorships, marketing programmes and similar marketing campaigns. We may also process and analyse your information that we have of you to understand your usage trends and preferences, and to develop and market (either ourselves or through our group companies, our business partners or any other third parties) new products, services, features and functions to you based on such analysis of your Personal Information.

LINKS TO OTHER SITES

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 Jupiter Platform which are operated by third parties and are not controlled by, or affiliated to, or associated with Jupiter unless expressly specified on the Jupiter Platform.

Jupiter is not responsible for any form of transmission, whatsoever, received by you from any Other Websites. Accordingly, Jupiter does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such third party websites, nor does Jupiter 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 third party websites. The inclusion or exclusion does not imply any endorsement by Jupiter of the Other Websites, the website's provider, or the information on the third party website. The information provided by you to such third party 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 third party prior to using such websites.

DATA RETENTION

Notwithstanding anything to the contrary mentioned elsewhere in this policy, Jupiter 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 combined information by Jupiter is determined by considering compliance with legal (contractual, statutory or regulatory requirements), accounting and compliance reporting requirements. Retention of your combined information will also be applicable pursuant to cancellation/ deactivation/ non subscription of your account with us or with our business partners.

YOUR RIGHTS

Jupiter seeks to provide reasonable assistance to cater to request from you regarding the processing of your Personal Information and the right to amend and withdraw permission to the processing of your Personal Information. In accordance with applicable laws and as per our policies, you can exercise the following right:
Access to your information You may request record of your Personal Information being processed by us, upon the verification of your identity and other information as per the Company internal policy
Review, Correct and Rectify your information You may review, correct or rectify the inaccurate Personal Information that is stored with us
Withdrawing your consent (a)You may withdraw a consent to processing that you have given us and prevent further processing of your Personal Information subject to the terms of this Privacy Policy; (b) You may also withhold your consent prior to the collection and processing of your combined information
You can exercise any of the aforementioned rights by submitting a request to privacy@jupiter.money; These rights are limited in some situations, such as, where we are legally or otherwise bound to process or retain your Personal Information. This may also affect our ability to provide you service and therefore may lead to discontinuation of the Service you procure from Jupiter.

SECURITY PRECAUTIONS

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.

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 Jupiter Platform.

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 Jupiter Platform; and you do so at your own risk.

CHANGES TO PRIVACY POLICY

Jupiter reserves the 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, Jupiter shall update the same on the App and Website. Please revisit App and Website 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 Jupiter Platform or Services constitutes your acceptance of the changes and the amended Privacy Policy. However, if you do not agree with the changes, please do not continue to use the Jupiter Platforms or Services or submit information to us and notify us about your disagreement over an email and upon confirmation from the Company your access to the Platform is suspended.

It is very important that any Personal Information we hold about you is up to date and correct. Please inform us of any changes to your Personal Information over an email or update your information on the Platform.

CREDIT FACILITIES

  1. The Jupiter App may facilitate various banks and NBFCs (collectively “Lending Partners”) in providing loans including “On Demand Salary” or “ODS” (“Credit Facilities”) to its Users. In addition to this Privacy Policy You may also be subject to the privacy policy of the the respective Lending Partners .
  2. The data collected or used by Us while facilitating the Credit Facilities is need based.
  3. We may use Your information including Personal Information provided by You while using Services (other than the Credit Facilities) on the Jupiter App.
  4. In relation to the data provided by You exclusively for the Credit Facilities, storage of the data including the type of data that can be stored and the length of time for which data can be stored shall be mutually agreed between Jupiter and the respective Lending Partners.
  5. As a DLA / LSP, We do not access mobile phone resources such as file and media, contact list, call logs, telephony functions, etc. in relation to the Credit Facilities.
  6. We do not collect, read, store or share with third parties Your personal SMS, other than the SMS pertaining to Your financial transactions solely to assist Our Lending Partners in assessing Your credit risk;
  7. We shall also take one-time access of certain features of Your mobile phone to facilitate on-boarding on the platform and KYC verification:camera, microphone, location, SMS, IP Address.
  8. No Personal Information of Yours containing biometric data will be collected or stored by Us unless permitted by extant statutory guidelines.
  9. All data is stored within servers located in India
  10. In case You have availed only Credit Facilities through Jupiter, You may request Us to delete Your information by submitting a request by sending an email at privacy@jupiter.money On submitting a request to delete Your account, You confirm and understand that:
    1. You have no outstanding credit facility availed through Us
    2. You have no pending or potential grievances in relation to any of Your previous dealings with Us, any of Our representatives, or Our Lending Partners.
    3. Your account will be permanently deleted. We will not be able to reactivate Your account.
    4. You will receive no further communications from Us or any of Our representatives.
  11. We are ISO 27001:2013 certified (“ISO”). Therefore, You may be assured that in case We become aware of any security breach of Your data, We shall take all measure to in line with the aforementioned protective standards.
  12. You understand that We will be required to or retain, and accordingly use and disclose any specific data if required by law, rule, regulation, law, enforcement, governmental official, legal, or regulatory authorities and / or to such other statutory bodies who have appropriate authorisation or for the purposes of completing any legal obligations or for audit requirements. We will not retain Your Personal Information for longer than is required for the purpose for which the information may lawfully be used.
  13. Sharing of data:
    1. We may appoint following sub-contractors or technology service providers to facilitate Credit Facilities with whom Your data will be shared with:
      1. Amazon Web Services
      2. Clevertap Private Limited
      3. Equifax Credit Information Services Private Limited
      4. Gupshup Technology India Private Limited
      5. Hyperverge Technologies Private Limited
      6. Karza Technologies Private Limited
      7. Ozonetel Communication Private Limited
      8. Razorpay Software Private Limited
      9. Unistanz Software Private Limited
      10. PayU India Innovations Private Limited
    2. We also provide collection services for Our Lending Partners. We may appoint the following agents to remind You of Your over due payments or help you out with other alternate options including debt counselling:
      1. Creditron Services Private Limited
      2. Statelabs Analytics Ventures Private Limited
      3. Captris Management Services LLP
      4. MTS Associates
      5. Dignity Solutions
      6. RKS Infra Solutions
      7. Micro Management Associate

HOW TO CONTACT US

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below for your reference:

Mr. Rajesh R Singh
Amica Financial Technologies Private Limited
3rd Floor, Above HDFC Bank, Viraj Building,
SV Road, Khar West, Mumbai – 400052
E-mail ID: - privacy@jupiter.money
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