Privacy Policy

Last Updated: 19th Jan 2023

GENERAL

IAltinvest Private Limited, a private limited company, incorporated under the provisions of the Companies Act, 2013, having its registered office at 508, 5th Floor, Eros City Square, Rosewood City, Sector 49-50, Gurugram - 122018, Haryana, India and its Affiliates/Subsidiaries/Associates including but not limited to Moolaah, (hereinafter referred as "We", "Us", "Our", or "Company" or "Moolaah") owns, operates and manages a website having domain name https://www.moolaah.com/ and related software application for use on wireless computing devices such as smartphones and tablets and also for use on desktop or laptop computers under the name and style of "Moolaah" (collectively hereinafter referred to as "Platform" or "Application").

The Platform facilitates and enables the User in availing certain online products and services from the Platform, including, inter alia, investment and wealth management services to the Users ("Services"), in accordance with the terms and conditions of use/Service of the Platform, as available at https://www.moolaah.com/terms-of-services("Terms of Use").

For the purposes of this privacy policy (hereinafter referred to as "Privacy Policy" or "Policy"), wherever the context so requires, references to the terms "User(s)", "You" or "Your", shall mean and include the user, registered on the Platform, who uses or access the Platform or avails the Service(s) (as defined below) of the Platform in accordance with the Terms of Use.

This Privacy Policy is published in compliance with the Information Technology Act, 2000, and applicable amendments, rules, regulations and guidelines enacted thereunder from time to time (“IT Act”) with specific mention of regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive personal information) Rules, 2011, and any other national and state laws which relate the processing of data. This Privacy Policy is an electronic record in terms of the IT Act and this electronic record is generated by a computer system and does not require any physical or digital signatures. Any new features and/or services that are added to our current service at any point in the future shall also be subject to the terms set out in this Policy along with any other future relevant legislation to be incorporated as per the laws of the land. This Privacy Policy shall apply to any person who visits, browses, uses or accesses the Platform or use any Services on the Platform.

This Privacy Policy, inter alia, states: (i) the type of information collected from the Users, including personal information and sensitive personal data or information (as defined below), relating to an individual; (ii) the purpose, means and modes of collection, usage, processing, retention and destruction of such information; (iii) how and to whom We will disclose such information; and (iv) how We will protect the Users’ personal information when they access the Platform.

Moolaah does not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to Moolaah. If Moolaah learns that we have collected personal information from a person under age 18, we will delete that information as quickly as possible. If you believe that a person under 18 may have provided us with personal information, please contact us at info@moolaah.com

PURPOSE AND SCOPE OF PRIVACY POLICY

This Privacy Policy is published to inform and describe Our Users of Our policies and procedures regarding collection, storage, and processing and sharing of information that We receive from our Users on the Platform or those which are stored or accessed by Us at the time of availing/ registering for the Services or making transactions on the Platform. We have developed this Policy to familiarize You with Our practices and demonstrate Our commitment to the protection of Your privacy and Your personal information. With regard to this Privacy Policy, the terms "using”, and "processing" information include, without limitation; the use of cookies; and the collection, storage, transfer, evaluation, deletion, disclosure, management, handling, modifying and use of information.
The below mentions the outlined idea of Scope of the Privacy Policy:

● This Privacy Policy is applicable to all Users of this Platform. By using the Services, registering with Us or by otherwise giving Us Your information, You shall be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by the terms hereof as laid down.

● We respect Your need to understand how and why information is being collected, used, disclosed, transferred and stored. This Privacy Policy sets out the way in which We process Your information when You visit the Platform or use the Services in accordance with applicable relevant data protection laws. By accessing Our Platform or availing the Services, You agree to be bound by the terms of this Policy.

● It is essential that You read this Policy, as well as any other policies We may provide on specific occasions when We collect or process your personal information, to ensure that You understand how and why We use your personal information.

● This Privacy Policy applies only to information that You provide Us via the Platform. We reserve the right to update this Privacy Policy from time to time to reflect any changes to Our Services. We will do this by amending the Privacy Policy on the Platform and intimate the changes which will take effect automatically as soon as they are posted on the Platform. In addition, We shall notify all Our users Users by email or any specified mode of communication with respect to the changes that are made to the Policy.

● The information on this Platform, as well as the information gathered by using/logging in and/or accessing it, is stored on a secure server. The server service provider claims to have implemented all of the best security practises for the server. We own the Platform, which is based in India. As a result, we are obligated to follow the laws governing privacy in India, including but not limited to regulations, rules, circulars, and notifications governing privacy in India.

● This Privacy Policy does not apply to any third-party website(s) and mobile app(s). You are requested to take note that information and privacy practices of Our business partners, advertisers, sponsors or other sites to which We provide hyperlink(s), may be different from this Policy, Hence, it is recommended that You review the Privacy Policy of any such third parties before You interact with such interfaces. Under such circumstances we kindly recommend you to read the policies on the applicable / relevant websites or sources.

You agree that We may collect, use, share, and disclose Your information in the ways set out in This Policy. If You do not agree to this Privacy Policy at any time, please do not use any of the services, use or access the Platform, or provide Us with any of Your personal information.

PURPOSE AND SCOPE OF PRIVACY POLICY

In order to enable a User to have access to the features, benefits or use of the Services on Our Platform, the User may require to provide certain information on the Platform which may constitute ‘personal information’ or ‘sensitive personal data or information’ of a person which shall be governed under regulation 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive personal information) Rules, 2011 , along with other relevant data privacy laws of the land and Prevention of Money Laundering Act (PMLA) 2002.

We may collect the following categories of personal information or sensitive personal data or information from the User but not limited to:

ON BOARDING / REGISTRATION OF SERVICES:	When You create a new account to use the Services we request for the following information: ● Name, DOB, Gender, Nationality, Father’s name, Mother’s name, Marital status, photo; ● Address, ZIP/postal code, location, phone number, e-mail id, your contacts and nominee details; ● Bank account number, your name on bank passbook and IFSC code of the bank; ● PAN card number, Aadhar card number (redacted), KYC related information either through videos or other online/ offline verification documents as mandated by relevant regulatory authorities, for the services you shall be utilizing (purpose of investments & transactions) and your businessrelated information. ● Employment related details (e.g. occupation, income, employer details, designation) as part of our record retention for Central KYC Records Registry (CKYCR) purposes under Prevention of Money Laundering (Maintenance of Records) Rules, 2005 ● Information in relation to Your device by way of using our app like, communication information including contacts and call logs, device information (including storage, model, mobile network), browser plug-ins, and cookies or similar technologies that may identify your browser Application and plug-ins, notifications etc.
KYC DETAILS:	● To comply with regulatory requirements, based on Your explicit consent we fetch Your KYC (Know Your Customer) details from regulated Registry
INVESTMENTS INFORMATION :	We provide the following options for you to update your investment information in a secure manner: ● Upload your investment statements that you get from Registrar & Transfer Agents such as Computer Age Management Services, Karvy Fintech Private Limited in PDF or Excel versions ● Enter the information manually: You provide investment details like scheme/scrip name, investment type, investment date and investment value by manually entering the data whenever necessary / applicable.

PROCESSING OF PERSONAL INFORMATION

We may process your personal information collected from you for, including without limitation, the following purposes:

Components	Reason for processing the Data
Services opted in Platform (investments, deposits, transactions etc)	● To facilitate your requests with respect to our varied range of financial products and services offered by us. For example, personal information is processed in order to organize and aggregate the User’s financial information in one place on the Platform, facilitate the Platform to provide the User analytics on their investments, help the User to assess their risk profile from time to time, create the User’s investment plans and make decisions on investments.
Value Added services	● to provide information to our Affiliate companies and its authorised agents and other third-party services providers so far as required for providing information about products/services of our Affiliate companies and / or to offer similar services and to provide you with various value-added services and information including for authentication purposes to enable linking of Your products held with Us.
KYC compliance	● to conduct the KYC compliance process as a mandatory prerequisite as per the requirements of various regulatory bodies, to validate, process and/or share Your KYC details, nominee details with other intermediaries, Regulated Entities or financial institutions or with any other service providers as may be required;
Sharing /Communication	● by sharing the information, You are allowed to contact either through Us or our third-party service providers through any channel of communication including but not limited to email, telephone, sms, etc.
Alerts/ notices	● to intimate and deliver You any administrative notices, alerts, advice and communications relevant to Your use of the Service; ● to send You important notices and communications regarding Our services availed or changes to the terms and conditions and/or policies, to administer Our business and Platform;
Customisation of platform/ offers	● to customize the content of Our Platform, request You for reviews of the Services; send You verification message(s) or email(s) validate/authenticate Your account and to prevent any misuse or abuse, ● to contact You on Your birthday and/or anniversary to inform You of any special offers if any available;
Compliance with applicable laws	● to deal with enquiries and complaints raised by You and to troubleshoot problems, ensure compliance with all applicable laws and to ensure safety of the Platform and all Users, to prevent fraud, errors and/or any illegal activity on the Platform, for conducting audits and for record keeping purposes

DISCLOSURE OF DATA

It may be necessary for Us to disclose Your personal information whether by law, legal process and/or by request from public and/or governmental authorities within or outside of your country of residence. We may also disclose Your personal information if We determine that disclosure is necessary or appropriate for the purposes of law enforcement, national security or to prevent or stop any activity We may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.

● Some sections of the Platform are open to all Users and visitors and do not require prior registration. Furthermore, Users can only access certain sections of the Platform after entering their information, username, and password. To ensure the security of Your username, password, and other information, we ask that you access the Platform through a safe and secure server.

● We do not guarantee the security and/or privacy of any information, which may be available to all Users and visitors of the Platform publicly. Further, the Platform may contain links to other websites. Please note that we do not endorse any links or websites and are not responsible for the privacy practices of such third-party websites.

● We automatically receive the URL of the site from which anyone visits. We also receive the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide Web), User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of User’s ISP. This information is used to analyse overall trends to help Us improve Our Services. The linkage between User’s IP address and User’s personally identifiable information is not shared with or disclosed to third parties. Notwithstanding the above, We may share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow Our business.

● Please be aware that we have a strict no-spam policy and do not rent, sell, disclose, or share personal information about You with other people or non-affiliated companies without Your consent, unless it is to provide you with the Services you have requested or as otherwise specified in this Policy.

You agree that in addition to as may be provided in this Policy, We may also disclose Your personal information under the following circumstances:

● Third party service professionals and/or providers: We engage, retain or might, as per requirement and business needs of the Company, employ, engage, contract with third party service professionals/providers to work on behalf of or with Us, under agreements containing confidentiality obligations and in accordance with law, in relation to the services provided by Us on the Platform. These third-party service providers may use Your personal information in assisting Us to communicate with You about Our offers, feedback of Services, assisting in payment facilities, providing customer support, assisting in advertising on the Platform etc. We may employ third party companies and/or individuals to help improve or facilitate our service, to provide the Service on our behalf, to perform platform-related services, including but not limited to: payment processing, maintenance services, fraud detection services, database management, web analytics, monitoring, delivery/logistics and evaluation services. In this event, your information may be shared with such third-party companies and/or individuals;

● Compliance with laws and protection of Users: We may release your personal information when the same is required in order to comply with the law, in response to court orders, court summons, judgments, decrees, injunctions, arbitral awards, administrative orders, governmental investigation or orders of any government authority or any other legal process, to establish/exercise Our legal rights or defend against legal claims or in the event We reasonably believe that doing so is legally required or is in your interest to protect Your property or other legal rights or property or rights of others. We may also share your personal information in order to enforce and fully comply with Our terms of service and other Company policies;

● Business transfer and mergers: We may transfer Your personal information if the Company, is acquired by or merged with another Company, to the extent permitted by applicable law and/or required under the scheme/arrangement of merger, etc. In such an event We will notify You before Your personal information is transferred/shared with the other entity and hence becomes subject to a different Privacy Policy;

● Contracting parties: We transfer/share Your information with Our service professionals, group companies or business partners to facilitate the availing/provision of Services by You.

● With Your consent in addition to the aforementioned circumstances, We may share Your personal information with third parties with Your prior consent and/or at Your request if necessary at future course of time.

COLLECTION AND USE OF NON-PERSONAL DATA

Non-personal data is data that can never be used to identify an individual. We may collect information regarding customer activities on Our Platform. This aggregated information shall be used by Us in research, analysis, to improve and monitor Our services and for various promotional schemes and offers. Such non personal data may be shared in aggregated, non-personal form with third party to enhance customer experience, offerings or services. The Platform uses cookies, and while using the Platform You will be prompted to accept all cookies. We may place text files in the browser files of Your computer system.

COOKIES POLICY

A cookie itself does not contain personal information and it will only enable Us to relate Your use of the Platform and Your behaviour on the Platform to information that You have specifically and knowingly provided. The only personal information that a cookie can contain is the information You supply to the cookie. A cookie can’t read data off Your hard disk or read cookie files created by other websites.

We may place both permanent and temporary cookies. A permanent cookie will remain on Your web browser until its expiry date, unless deleted prior to such expiry date. However, most cookies are “session cookies” meaning that they automatically get deleted from your computer system at the end of the session. You can refuse cookies by turning them off in Your browser or alternatively You can also set your browser to warn You before accepting any cookies. Therefore, You are always free to decline Our cookies if Your browser permits, however We use certain cookies to authenticate Users on each page after the User logs on to the Platform or accesses any Services. If you, as a casual visitor, have inadvertently browsed any other page of this Platform prior to reading this Privacy Policy, and you do not agree with the manner in which such information is obtained, collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by Us. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as We cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Platform. Please note that You are not a casual visitor if you have willingly submitted any personal information or information to Us through any means, including email, post or through the registration process on the Platform. All such visitors will be deemed to be, and will be treated as Users for the purposes of this Privacy Policy, and in which case, this Privacy Policy applies in its entirety to such persons.

The data that cookies collect will be used to process and/or analyse information by third parties to help improve or facilitate Our services, to provide Service on Our behalf, to Platform-related services, including but not limited to; maintenance services; fraud detection services; database management; web analytics; monitoring; and evaluation services. If you have any questions about Our cookie usage, please contact Us at the contact details/information mentioned below.

YOUR RIGHTS AND HOW TO EXERCISE THEM

DISCLAIMER OF INFORMATION

We respect the exercise of the rights You have in relation to the personal data and information We process or use. You can request access to or a copy of your personal and information collected and processed by Us. You can also request for the correction and deletion of your personal data and information, as well as the restriction of their processing. Users have the right to unilaterally change their e-mail and contact preferences at any time by logging into their "Account" on the Platform and changing the account settings. You also have the right to data portability. If You have an objection to use of Your data under this Policy, please write to Our privacy team at contact information given below. To prevent misuse, We will ask You to identify yourself.

You are responsible for maintaining the accuracy, truthfulness, correctness and completeness of the information You submit or provide to Us, on the Platform; and shall hold harmless and indemnify Us from and against all claims arising out of or in relation to the wrongful information posted, provided by You to Us, on the Platform. If Your personal information changes, You may correct, delete inaccuracies, or amend information by making the change on Our member information page or by contacting Us on the contact information given below. There may be circumstances where We will not correct, delete or update Your personal data information, including; (i) where the personal data and information is opinion data that is kept solely for evaluative purpose; and (ii) the personal data information is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed. If you wish to cancel your account or request that We no longer use your information to provide you Services, you may contact us on the contact information given below.

SECURITY

We understand the serious implications of data security and take extensive measures to ensure Your data and information is secured. We take extensive technical and legal measures to safeguard Your personal data and information.

● The Platform uses a reliable SSL certificate to ensure Your personal data and information is not misused in any manner whatsoever. We use SSL encryption when transmitting certain kinds of information, such as financial services information or payment information.

● Our employees and data processors who have access to or are associated with the processing of sensitive personal data or information are required to keep the privacy of each User's personal information or sensitive personal data and information confidential.

● We have put in place procedures and technologies to ensure the security of all personal data and information from the point of collection to the point of destruction, in accordance with industry best practises and applicable laws. Any third-party data processor to whom We send personal data and information must agree to follow those procedures and policies or take appropriate measures on their own.

● No administrator of the Platform will have knowledge of Your OTP. It is important for You to protect against any unauthorized access to Your OTP, Your contact details and Your mobile phone. Ensure You log off from the Platform when finished. We do not undertake any liability for any unauthorized use of Your account.

● If You suspect any unauthorized use of Your account, you must immediately notify Us by sending an email to info@moolaah.com . You shall be liable to indemnify Us due to any loss suffered by Us due to such unauthorized use of Your account. Please note that We make all User information accessible to Our employees, agents or partners and third parties only on a need-to-know basis and binds only its employees to strict confidentiality obligations. However, We are not responsible for the confidentiality, security or distribution of Your personal information by Our partners and third parties outside the scope of Our agreement with such partners and third parties.

● In case there is any breach of security, We will make all legally required disclosures concerning the breach and the confidentiality, or integrity of Your unencrypted electronically stored "personal information" to You via email or By posting it on Platform without any unreasonable delay, in as far as is consistent with any legitimate needs of law enforcement and any measures required to determine the scope of the breach and to safeguard the integrity of data.

● Moolaah is dedicated to protecting our clients' data and privacy. To ensure that our systems maintain strong security measures, we combine security at multiple steps within our products with cutting-edge technology. The overall data and privacy security design enables us to defend our systems against a wide range of threats, from low-hanging fruit to sophisticated attacks.

● If you are a security enthusiast or a researcher and you have found possible security vulnerability on Moolaah, we encourage you to report the issue to us responsibly. You could submit a bug report to us at info@moolaah.com with detailed steps required to reproduce the vulnerability.

CHILDREN:

This website is not intended for use by children and minors. Parents are requested to ensure that Personal Information is not provided by minors.

COMPLIANCES

We have implemented required Information Systems Management System policies and procedures in order to maintain industry standard best practices and applicable controls as necessary for protecting the data of Our Users.

We will also be undergoing annual security assessment from a third party and keep the same updated from time to time or as per instructions from the assessor and will publish the “letter of assessment” on Moolaah website and mobile applications.

RETENTION PERIOD

We do not keep your personal data and information longer than necessary for the purpose of the processing except for any record retention required by applicable laws, including but not limited to Securities and Exchange Board of India (Investment Advisers) Regulations 2013 and Prevention of Money Laundering Act 2002. This includes, for example, the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to carry out legal work, for the establishment or defence of legal claims. We may aggregate and anonymize your personal data and information (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

CHANGES IN PRIVACY POLICY

We reserve the right to change the Policy at any time. You may note that this Policy itself and any such change of policy will be effective from the date of posting on the site.

Any changes shall be effective immediately upon the posting of the revised Privacy Policy. While We will make reasonable efforts to keep You posted on any updates to this privacy policy, to make sure that You are aware of any changes, We recommend that You review this policy periodically. If You are not comfortable with any of the changes to Privacy Policy, You may choose to discontinue usage of Moolaah website or mobile applications. You can also email us at info@moolaah.com to update or delete Your personal information that Moolaah has collected.

QUESTIONS OR COMPLAINTS

If you have any question or complaints about the processing of your personal information, write to us at info@moolaah.com. Our team will be happy to assist you.

CONTACT INFORMATION

Address: 508, 5th Floor, Eros City Square, Rosewood City, Sector 49-50, Gurugram - 122018, Haryana, India

Email: info@moolaah.com

GRIEVANCE OFFICER

In accordance with the provisions of the Information Technology Act, 2000, and rules made thereunder, the name and contact details of the Grievance Officer are provided below: Attn:
Designation: Grievance Officer
Email: info@moolaah.com
Time: Mon - Friday (9.30 AM – 5.30 PM)
Address: 508, 5th Floor, Eros City Square, Rosewood City, Sector 49-50, Gurugram - 122018,
Haryana, India