INVULB Technologies Private Limited, is a private limited company operating from the registered office
at Flat 401, Aditya Imperial Heights, Carlton C Block, Hafeezpet, Hyderabad, Telangana, India-500049,
(hereinafter referred to as “Company”, “We”, “Us” or “Our” which expression shall include its
affiliates, subsidiaries, successors and assigns). The Company owns and operates the
website
www.INVULB.com and/or the mobile application ‘INVULB’ (collectively referred to as the
“Platform”). “You” and “Your” shall mean anyone who visits, accesses, or uses the Platform or obtains
Services (defined below) from Us through the Platform. We are committed to protecting Your privacy and
the information You share with Us while using and operating the Platform. We value the trust You place
in Us and thus We maintain the highest security standards for securing the transactions and Your
information.
We may also allow Our group companies, affiliates and subsidiary companies to use Our Platform to offer
their products and services to You, under applicable terms and conditions as may be specified on Our
Platform from time to time.
This privacy policy (“Privacy Policy”) specifies the manner in which personal data and other information
are collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by
the Company. This Privacy Policy does not apply to information that You provide to, or that is collected
by, any third-party (excluding the group companies, affiliates and subsidiary companies) through the
Platform, and anyThird-Party Sites that You access or use in connection with the services offered on the
Platform. Please read the Privacy Policy carefully prior to using or registering on the Platform or
accessing/availing the services made available on the Platform including, among other things, mutual
fund distribution, stock broking services (“Services”).
By accessing the Platform and/or using the Services, You accept and agree to be bound by the Terms and
conditions of this Privacy Policy. This Privacy Policy is incorporated into and shall be subject to the
General Terms & Conditions of the Platform (“Terms”). The Privacy Policy shall be read harmoniously and
in conjunction with the Terms.
This Privacy Policy (i) is an electronic record under the Information Technology Act, 2000 read with
rules and regulations made thereunder and is generated by a computer system; and (ii) will not require
any physical, electronic, or digital signature. In case of any non-compliance of the Privacy Policy by
You or any of your representatives, We shall have the right to terminate Your access to the Services or
any part thereof or Your usage rights to the Platform immediately or remove non-compliant information or
both, as the case may be.
We may collect Personal Information, Transaction Information and Non-Personal Information (defined
below)from You when You register or set up an account with Us on the Platform or when You avail the
Services. You can browse certain sections of the Platform without being a registered member,
however, to avail certain Services on the Platform (such as investing in Mutual funds, Stocks and/or
Digital Gold & Silver) You are required to register with Us.
This Privacy Policy applies to the following information:
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Information You provide Us:You may provide certain information to Us voluntarily while
registering on Our Platform or for using Our Services. Such information include any
identification/ correspondence details including Your mobile number, email address, password,
date of birth, gender, Permanent Account Number (PAN), signature, marital status, nominee
details, residential/ current address, any national identifiers such as identity card / passport
details / Aadhaar card details
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Voter ID / driving license, and/or education details. We may also ask You to provide certain
additional information about You or any person acting on Your behalf on a case-to-case basis
(collectively “Personal Information”). Further, You hereby acknowledge and agree that Our
affiliates or group or subsidiary companies registered with financial services regulators may
retrieve from Your records available with third party including from Know Your Customer (KYC)
Registration Agency (KRA) such as name, KYC details, KYC status, father’s name, occupation,
address details and related documents.
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Transactional Information:We may also ask You for certain financial information, including Your
billing address, bank account details, income, expenses, and/or credit history, including
transaction history, balances, and/or other payment related details or other payment method
data, and debit instructions or other standing instructions to process payments for the
Services. Further, if You choose to invest through the Platform, We will also collect
information about Your transactions including transaction status/ ID and details and Your
investing patterns and behaviour (collectively “Transaction Information”).
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Non-Personal Information and Cookies: We may also collect certain non-personal information, such
as Your internet protocol address, web request, operating system, browser type, URL, internet
service provider, IP address, aggregate user data, browser type, software and hardware
attributes, pages You request, and cookie information, etc., which will not identify with You
specifically (“Non – Personal Information”), while You browse, access or use the Platform. We
receive and store Non – Personal Information, using data collection devices such as “cookies” on
certain pages of the Platform, in order to help and analyze Our web – page flow, track user
trends, measure promotional effectiveness, and promote trust and safety. We offer certain
additional features on the Platform that are only available through the use of a “cookie”. We
place both permanent and temporary cookies in Your computer’s hard drive. We also use cookies to
allow You to enter Your password less frequently during a session on the Platform. Most cookies
are “session cookies,” meaning that they are automatically deleted from Your hard drive at the
end of a session. You are always free to decline Our cookies if Your browser permits, although
in that case, You may not be able to use certain features or Services being provided on the
Platform or You may be required to re-enter Your password each time you log – in or access the
Platform during a session. No Personal Data will be collected via cookies and other tracking
technology; however, if You previously provided Personal Data, cookies may be tied to such
information. When and if You download and/or use the Platform through Your mobile device, We may
receive information about Your location, Your IP address, and/or Your mobile device, including a
unique identifier number for Your device. We may use this information to provide You with
location- based Services including but not limited to search results and other personalized
content. You can withdraw Your consent at any time by disabling the location-tracking functions
on Your mobile. However, this may affect Your use/ enjoyment of certain features on Our
Platform. You acknowledge and agree that when You browse the Platform without being a registered
member or without providing Your Personal Information, We may still collect and store Your
Non-Personal Information.
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User Communications: If You choose to post messages on our message boards, chat rooms or other
message areas or leave feedback or if You send us correspondence, such as emails or letters, or
if other users or third parties send us correspondence about Your activities or postings on the
Platform (“User Communications”), We will collect and store such information You provide to Us.
We retain this information as necessary to resolve disputes, provide customer support, respond
to queries and inquiries, and troubleshoot problems and improve the Services. Any communication,
post, comment or correspondences made by You while making use of Our Platform or availing the
Services including but not limited to providing any general feedback or any communication with
our customer service executive including any integrated artificial intelligence feature offered
by the Platform/ chatbot may be collected by us and retained as per the terms of this Privacy
Policy.
All information disclosed by You including but not limited to Your Personal Information,
Non-Personal Information, User Information and Transaction Information shall be deemed to be
disclosed willingly and without any coercion. No liability pertaining to the
authenticity/genuineness/misrepresentation etc. of Your Personal Information provided to Us or with
regard to any fraud or negligence thereof shall lie on the Company nor will the Company be in any
way responsible to verify any information obtained from You. All information disclosed by You
including all collected by the Company shall be stored on servers, log files and any other storage
system owned by the Company or by our third party partners in India. Our primary goal in doing so is
to provide You a safe, efficient, smooth and customized experience on the Platform. The information
collected by Us allows Us to provide the Services and features on the Platform that most likely meet
Your needs, and to customize the Platform to make Your experience safer and easier.
Wherever possible, while providing the information to Us, We indicate which fields are mandatory and
which fields are optional for You. You always have the option to not provide the Personal
Information to Us through the Platform by choosing to not use a particular Service or feature being
provided by Us on the Platform, which requires You to provide such information.
We use the Personal Information, Non-Personal Information, Transactional Information and User
Communications and such other information provided by You for the following:
- to provide and improve the Services on the Platform that You request;
- to resolve disputes and troubleshoot problems;
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to help promote a safe service on the Platform and protect the security and integrity of the
Platform, the Services and the users;
- collect money from You in relation to the Services, wherever applicable
- inform You about online and offline offers, products, services, and updates;
- customize Your experience on the Platform or share marketing material with You;
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to detect, prevent and protect Us from any errors, fraud and other criminal or prohibited
activity on the Platform;
- enforce and inform about our terms and conditions;
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to process and fulfil Your request for Services or respond to Your comments, and queries on the
Platform; to contact You;
- to allow Our business partners and/or associates to present customised messages to You;
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to communicate important notices or changes in the Services, use of the Platform and the
terms/policies which govern the relationship between You and the Company and with Our affiliates
for providing Services to You; and (xiii) for any other purpose after obtaining Your consent at
the time of collection.
You hereby specifically agree and provide Your consent thereby enabling Us and/or our group
companies, subsidiaries, affiliates to collect, store, transfer, process and share information
(including Personal Information) related to You with third parties such as Banks, financial
institutions, credit information companies, entities registered under applicable laws with
Securities Exchange Board of India, National Stock Exchange of India Limited/BSE
Limited/MMTC-PAMP/Central Registry of Securitisation Asset Reconstruction and Security Interest of
India (CERSAI)/payment gateways/ collecting banks/KRAs etc. solely for the purpose of reviewing your
profile and processing your transaction requests for the Services or for other products/services
offered by us or our group companies, affiliates and subsidiary companies.
We may automatically track certain information about You based upon Your behaviour on the Platform.
We use this information to do internal research on Your demographics, interests, and behaviour to
better understand, protect and serve You. This information is compiled and analysed by the Company
on an aggregated basis and not individually, in a manner that does not specifically identify You. In
addition to the above, We identify and use Your IP address to help diagnose problems with Our
server, resolve such problems and administer the Platform. Your IP address is also used to help
identify you and to gather broad demographic information.
We may occasionally ask You to complete optional online surveys. These surveys may ask You for Your
contact information and demographic information (like zip code, age, or income level). We use this
information to 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. We use Your Personal
Information to send You promotional emails, 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 and Your account on the Platform.
Unless and until, You explicitly give Your consent to Us, to do so, We will not share Your Personal
Information with another user of the Platform and vice versa.
Use of information received by the Company and/or its affiliates or subsidiary companies from Google
APIs will adhere to Google API Services User Data Policy including the Limited Use requirements.
We may make Your Personal Information, Non-Personal Information, Transaction Information,
UserCommunications and/or other information available to group companies, affiliates and subsidiary
companiesincluding but not limited to INVULB Technologies Private Limited (“INVULB”), FINVULB
Technologies Private Limited. (“FINVULB”) to enable providing You Services through the Platform.
Please note that all information shared with group companies, affiliates and subsidiary companies or
made available to group companies, affiliates and subsidiary companies will be governed by this
Privacy Policy. In addition to the Personal Information and in order to provide Services to You,
INVULB may also collect Your Aadhaar, finger – print details and signature solely for completing the
account opening procedures and authenticating Your transactions on the Platform. The act of
providing Your Aadhaar is voluntary in nature and the Company, hereby agrees and acknowledges that
INVULB will collect, use and store such details in compliance with applicable laws and this Privacy
Policy.
We may also disclose Your Personal Information, to authorised third party vendors, consultants, and
other service providers of the Company, who are bound by contractual obligations to keep such
personal information confidential and use it only for the purposes for which We disclose it to them
and You hereby give Your consent for the same. This disclosure may be required for Us, for instance,
to provide You access to Our Services and process payments including validation of Your bank
accounts, to facilitate and assist Our marketing and advertising activities/initiatives, for
undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent
or illegal activities related to Our Services.
You hereby specifically agree and provide Your consent thereby enabling Us and/ or Our
group/associate/affiliate companies to access, store, transfer, process your SMS data for the
purpose of reviewing your profile or doing internal evaluation and analysis. Further We and/ or Our
group/associate/affiliate companies may also share Your SMS data with third parties such as Banks,
NBFCs, Billers/Utility Service providers etc towards the services offered and You hereby give Your
consent for the same.
The Company may disclose Your information, to the extent necessary:
- to comply with laws and to respond to lawful requests and legal process,
- to protect the rights and property of the Company, Our users, and others, including to
enforce the Terms, and
- in an emergency to protect the personal safety and assets of the Company, the users, or any
person. In such an event the Company is in no manner responsible for informing You or
seeking Your approval or consent.
We and Our group companies, affiliates and subsidiary companies (to the extent Personal Information
is collected by them) may, in compliance with applicable laws, share/transfer/assign all of Your
Personal Information and other information with any other business entity(ies), in the event of a
merger, sale, re- organization, amalgamation, joint ventures, assignment, restructuring of business
or transfer or disposition of all or any portion of Our business.
You hereby choose to provide Your explicit consent to connect/integrate Your email account(s) with
Your account on the Platform by clicking on the authentication email sent by the Company on Your
registered email address. You may upload Your image on our platform for app functionality.
Such data obtained by this integration will be used by the Company solely for providing the Services
and improving Your experience of the features of the Platform and to consolidate your investment
details and history. The Company hereby agrees and acknowledges that it shall not use or transfer
any data or information received from the integration of the email addresses with the account on the
Platform to third parties for serving ads, including retargeting, personalized, or interest-based
advertising.
Our Platform may link You to other third – party Platforms (“Third – Party Sites”) that may collect
Your Personal Information including Your IP address, browser specification, or operating system. The
Company is not in any manner responsible for the security of such information or their privacy
practices or content of those Third – Party Sites. Additionally, You may also encounter “cookies” or
other similar devices on certain pages of the Third – Party Sites and it is hereby clarified by the
Company that the Platform does not control the use of cookies by these Third – Party Sites. These
third-party service providers and Third-Party Sites may have their own privacy policies governing
the storage and retention of Your information that You may be subject to. This Privacy Policy does
not govern any information provided to, stored on, or used by these third- party providers and
Third-Party Sites. We recommend that when You enter a Third-Party Site, You review the Third Party
Site’s privacy policy as it relates to safeguarding of Your information. We may use information (not
including Your name, address, email address, or telephone number) about Your visits to the Platform
and Third-Party Sites in order to provide advertisements about goods and services of interest to
You. You agree and acknowledge that We are not liable for the information published in search
results or by any Third-Party Sites.
Our Platform has reasonable security measures and safeguards in place to protect Your privacy and
Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration
of the information in compliance with applicable laws. Further, whenever You access Your account on
the Platform or any information relating to it, We offer the use of a secure server. We cannot
however ensure or warrant the security of any information You transmit to the Company or guarantee
that Your Personal Information and/or other Non-Personal Information provided for availing the
Services or accessing the Platform will not be accessed, disclosed, altered or destroyed by a breach
of any of Our security measures and safeguards. It is further clarified that You have, so long as
You access and/or use the Platform (directly or indirectly), the obligation to ensure that You
shall, at all times, take adequate physical, managerial, and technical safeguards, at Your end, to
preserve the integrity and security of Your data which shall include and not be limited to Your
Personal Information.
When Transaction Information is being transmitted on or through the Platform, it will be protected
by encryption technology. You expressly consent to the sharing of Your information with third party
service providers, including payment gateways, to process payments and manage your payment-related
information. We take various steps and measures to protect the security of your information from
misuse, loss, unauthorised access, modification or disclosure. We use latest secure server layers
encryption and access control on our systems. Please do not share your Account’s login, password,
OTP details or credentials with anybody.
While We observe reasonable security measures to protect Your Personal Information on all our
digital platforms, security risks may still arise for reasons outside of our control such as
hacking, virus dissemination, force majeure events, breach of firewall etc. Please note that the
above mentioned measures do not guarantee absolute protection to the Personal Information. The
Company assumes no liability or responsibility for disclosure of Your information due to errors in
transmission, unauthorized third-party access, or other causes beyond its control. You play an
important role in keeping Your personal information secure. You shall not share Your Personal
Information or other security information for Your account with anyone. The Company has undertaken
reasonable measures to protect Your rights of privacy with respect to Your usage of the Platform
controlled by Us and Our Services. However, We shall not be liable for any unauthorized or unlawful
disclosures of Your personal information made by any third parties who are not subject to Our
control.
You agree to notify us immediately in case of any unauthorized or illegal access/ use of your
account or any breach of security arising due to your action/ inaction. We shall notify you and/or
the appropriate authority in case of any breach of security, data at our end and in accordance with
such timelines as may be prescribed under applicable law(s)
This Privacy Policy and the security controls and practices implemented by Us to Protect Your
Personal Information shall be the reasonable security practices and procedures under section 43A of
the Information Technology Act, 2000.
- You shall not host, display, upload, modify, publish, transmit, store, update or share any
information that:
- belongs to another person and to which You do not have any right.
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is obscene, pornographic, pedophilic, invasive of another’s privacy including bodily privacy,
insulting or harassing on the basis of gender, racially or ethnically objectionable, relating or
encouraging money laundering or gambling, or promoting enmity between different groups on the
grounds of religion or caste with the intent to incite violence.
- is harmful to child.
- infringes any patent, trademark, copyright or other proprietary rights.
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deceives or misleads the addressee about the origin of the message or knowingly and
intentionally communicates any misinformation or information which is patently false and untrue
or misleading in nature.
- impersonates another person.
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threatens the unity, integrity, defense, security or sovereignty of India, friendly relations
with foreign
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States, or public order, or causes incitement to the commission of any cognizable offence, or
prevents investigation of any offence, or is insulting other nation.
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contains software virus or any other computer code, file or program designed to interrupt,
destroy or limit the functionality of any computer resource. violates any law for the time being
in force.
Your Consent: By visiting the Platform or setting up/creating an account on the Platform for availing the Services on the Platform at such time, You signify Your acceptance to the provisions of the Privacy Policy.
Withdrawal of consent: You may choose to withdraw Your consent provided hereunder at any point in time. Such withdrawal of consent must be sent in writing to In case You do not provide Your consent or later withdraw Your consent, We may request you not to access the Platform and/or use the Services and also reserve the right to not provide You any Services through the Platform. In such a scenario, the Company may delete Your information (Personal or otherwise) or de-identify it so that it is anonymous and not attributable to You. Notwithstanding anything contained herein, the Company may retain some or all of Your information in accordance with our policies and/or any applicable law(s).
Changes to Privacy Policy: We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time, without specifically notifying You of any changes. However, We may, at Our sole discretion, provide You push notifications or such other form(s) of notice as We deem necessary to keep You updated about this Privacy Policy. Any changes or updates will be effective immediately. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the “Updated” Date legend above. Your continued usage of the Platform shall signify Your consent to such changes and You shall be legally bound by the same.
If You have any grievance with respect to the Platform, please feel free to reach out to the grievance officer, the name and contact details have been provided below:
Please feel free to contact us at
contactus@INVULB.com regarding any questions on the Privacy Policy.
This policy will be governed by and construed in accordance with the laws of India and subjected to the exclusive jurisdiction of Courts of Telengana.