WEBSITE PRIVACY POLICY
Last Updated: January 12, 2021
  1. INTRODUCTION

    Multipl Fintech Solutions Private Limited (“Multipl”, “we”, “us”, “our” or “Company”) is a fintech company providing aggregated financial solutions and services to users through our Platform, as described in our terms of service ([hyperlink to terms of service]) (“Terms of Service”). We at Multipl are committed to protecting the privacy and security of its users (“user(s)”, “your”, or “you”). Your privacy is important and maintaining your trust is paramount to us. This Privacy Policy (“Privacy Policy”) explains how we collect, use, process, disclose, and safeguard your information when you use our our Services through our Platform through its website: ([hyperlink to website], which shall be incorporated into and subject to the Terms of Service and shall be read harmoniously and in conjunction. Any capitalized terms defined herein shall have the same meaning as prescribed in the Terms of Service.

    We strictly adhere to the requirements of the data protection laws and regulations (as may be amended) established in India and this Privacy Policy is published in accordance with:

    • Section 43A of the Information Technology Act, 2000 (“IT Act”);
    • Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the “SDPI Rules”); and
    • Rule 3 of the Information Technology (Intermediary Guidelines) Rules, 2011.

    Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using our Platform and our Services, you agree to accept all the terms contained in this Privacy Policy and acknowledge and agree with the practices described herein. If you do not agree with the terms of this Privacy Policy, please do not access and use, our Platform and our Services. This Privacy Policy describes our privacy practices for all websites, products and services that are linked to it. However this Privacy Policy does not apply to those affiliates and partners that have their own privacy policy. In such situations, we recommend that you read the privacy policy on the applicable website. Any capitalised terms not defined hereunder shall hold the same definition as provided under the Terms of Service.

    If you have any questions regarding this Privacy Policy, please send us an email at privacy@multipl.xyz.

  2. WHAT INFORMATION DO WE COLLECT?

    We collect Personal Information and Non-Personal Information (as defined below) from you when you register or set up account with us on our Platform. When you start using the Services, we ask you to provide certain information as part of the registration process, and in the course of your interface with the Platform. We will collect this information through multiple means and in various places through the Services, including but not limited to, account registration forms, contact us forms, or when you otherwise interact with Multipl, including at customer support.

    This Privacy Policy applies to:

    • Information that you may provide to us voluntarily while registering on our Platform for using our Services, including but not limited to, full name, mobile number, email address, password, photograph, audio file, location, date of birth, gender, Permanent Account Number (PAN), Aadhar details, e-KYC through UIDAI, CKYC through CERSAI, income/salary information, marital status, sexual orientation, biometric data, health status and nominee details. We may also ask you to provide your financial information, including but not limited to, billing address, bank account details, credit/debit card details, payment related details, payment method data, debit instructions, e-mandates, standing instructions or any other personal/financial information as required by various applicable laws and regulations from time to time to process the Services (“Personal Information”).
    • Certain additional information about yourself on a case to case basis. Further, when you visit our Platform, we may log certain non-personal information such as your IP address, cookie information, browser type, mobile operating system, manufacturer and model of your mobile device, geolocation, preferred language, access time and time spent. We will also collect information about the pages you view within our sites and other actions you take while using the Platform (“Non-Personal Information”). We receive and store Non-Personal Information, by the use of the data collection devices such as ‘cookies’ on certain pages of the Platform, in order to help and analyse our webpage flow, track user trends, measure promotional effectiveness, demographic studies and promote trust and safety. This Non-Personal Information is compiled and analysed by the Company on an aggregated basis and not individually, in a manner that does not specifically identify you.
    • Any information that is freely available, accessible in the public domain, furnished under the Right to Information Act, 2005 or any other law for the time being in forced, where such information shall not be regarded as sensitive personal data or information. We may also retrieve from your records available with third party Know Your Customer (KYC) Registration Agency (KRA), information such as your KYC details, KYC status, father’s name, occupation, address details and related documents.
    • All such Personal Information and Non-Personal Information described above, which shall be deemed to be disclosed willingly and without any coercion. No liability of any form pertaining to the authenticity/genuineness/misrepresentation/fraud/negligence, etc. of the Personal Information provided by you, shall lie on the Company, nor will the Company be in any way responsible to verify any information obtained from you.
    • The Company’s use of information received from Google APIs will adhere to Google API Services User Data Policy , including the Limited Use requirements.

    Please note that our Platform may link you to third-party websites/apps (“Third-Party Sites”), that may collect your personal information, for which the Company is not in any manner responsible for the security of such Third-Party Sites or their privacy practices or content. Such third-party provides Third-Party Sites may have their own privacy policies governing their 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 such Third-Party Sites or third-party providers and we recommend that you review the applicable privacy policy when you enter a Third-Party Site. You agree and acknowledge that the Company is not liable for the information published by any Third-Party Site. Nonetheless, we seek to protect the integrity of the App and our Platform and welcome any feedback at about these websites. Please contact us at privacy@multipl.xyz.

    We take care to allow your Personal Information and Non-Personal Information to be accessed only by those who really need it in order to perform their tasks and duties and to third parties who have a legitimate purpose for accessing it and with your consent. Your Personal Information and Non-Personal Information will be transferred only to a Third-Party Sites that ensures the same level of data protection that is mandated under the IT Act and the SDPI Rules.

  3. HOW DO WE USE YOUR INFORMATION?

    We use the Personal Information and Non-Personal Information provided by you:

    • To create your account, verifying your identity and process your transaction(s) on the Platform;
    • To provide you Advisory Services on the Platform;
    • To collect statistics about your usage of the Platform and its effectiveness;
    • To improve and personalise your experience of the Services, as well as customize our interactions with you to further expand the scope of the Platform;
    • To resolve disputes, provide customer support and troubleshoot problems that arise from using our Platform;
    • To help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users;
    • To collect the applicable fees from you in relation to the Services;
    • To inform you about online and offline offers, campaigns, programs, products, services and/or updates;
    • To customise your experience on the Platform or share custom marketing material with you;
    • To detect, prevent and protect the Company from any errors, frauds, and other criminal or prohibited activity on the Platform;
    • To enforce and inform you about our Terms of Service;
    • To process and fulfil your request for Services or respond to your queries on the Platform;
    • To contact you;
    • To allow our business partners and/or affiliated entities to present customised messages to you;
    • To communicate important notices or changes in the Services offered by the Company, use of the Platform, and the terms/policies which govern the relationship between you and the Company and with our affiliates; and
    • For any other purpose, for which you have granted access to such information to us, based on your interaction with Platform.

    We may send you text messages on your registered mobile number that you share with us. All text messages originating from us, where applicable, through our authorized third-party service providers will at all times be compliant with guidelines prescribed by the Telecom Regulatory Authority of India (“TRAI”). The nature of communication from us is broadly classified into two (2) categories:

    • Transactional SMS. Transactional messages are messages that carry your account and transaction specific information such as one-time passwords (OTP) in connection with registration for any of the Services or campaign related offerings, account status, invoice details, confirmation alerts, bank accounts status and other details in the form of real-time updates on the activities on your account. You may receive Transactional SMS even if you are a Do-Not-Disturb (“DND”) registered user.
    • Promotional SMS. You may also receive text messages in the event that you are a non-DND registered user. We may send you such text messages to update you on our service offerings that may be of interest for you.

    You specifically agree and consent to us collecting, storing, processing, transferring and sharing your Personal Information and Non-Personal Information for the aforementioned use-case.

  4. DISCLOSURE OF INFORMATION?

    We may disclose your Personal Information and Non-Personal Information, to the extent necessary:

    • To statutory and regulatory authorities to comply with applicable laws and to respond to lawful requests and due legal process;
    • To protect the rights, property and safety of the Company, our business and services partners and the users, including to enforce the Terms of Service;
    • To our subsidiaries and affiliates, in the ordinary course of business;
    • To third-party websites;
    • To third-party service partners, including business partners, affiliates, service providers, entities registered under applicable laws with Securities Exchange Board of India (SEBI), National Stock Exchange of India Limited, Bombay Stock Exchange Limited, authorized payment gateways, collecting banks, KRAs, credit bureaus, etc. for the purpose of billing and collection, providing content, products, customer support etc.;
    • In case of a corporate sale, merger, acquisition, sale of business, reorganization, dissolution, insolvency or such similar events;
    • To third parties to market their products/services/campaigns/programs, subject to whether users have either consented or not opted out of these disclosures;
    • To fulfil the purpose for which the user provided such information;
    • For any other purpose for which the User provided it;
  5. HOW DO WE RETAIN YOUR INFORMATION?

    We may store and retain your Personal Information and Non-Personal Information, to the extent necessary:

    • To carry out the Services for the user on the Platform. Generally, this means, we will keep your Personal Information and Non-Personal Information as long as your account is active or as needed to provide our Services;
    • Retain and use the information collected as necessary to comply with our legal obligations, resolve disputes or for other business purposes;
    • Retain your Personal Information and Non-Personal Information for [12] months after you cancel/ deactivate/ unsubscribe your account with us, as our business practice; and

    Where we have no continuing legitimate business need to process your Personal Information and Non-Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

  6. HOW DO WE PROTECT INFORMATION WE COLLECT?

    We are dedicated to guarding the security of your information and our Platform has several industry-standard security technologies and procedures devised to help protect your data from unauthorized access, use, destruction or disclosure, including technical and organizational security measures to protect the security of your personal data both online and offline. The App receives regular security scans and penetration tests. The App also receives regular malware scans. In addition, the App uses an SSL certificate as an added security measure. We require username and passwords for our employees who can access the personal information of Users that we store and/or process on the servers. In addition, we actively prevent third parties from getting access to the personal information of Users that we store and/or process on the servers. We will implement reasonable security measures every time you (a) place an order, (b) enter, submit, or access your information, (c) register, or (d) access the App.

  7. DATA SECURITY MEASURES

    Security Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the App and/or our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App.

    Fair Information Practice Principles. In the event of a personal data breach, we will notify the User within fifteen (15) days via (i) email and/or (ii) our Platform notification system on the App. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

  8. VIII.HOW DO YOU UPDATE YOUR INFORMATION?

    You specifically consent and agree that the Personal Information pertaining to your account on the Platform shall be both accurate and current. If you wish to update your Personal Information which is inaccurate or incorrect, we shall provide self-help tools for you to directly review or update certain aspects of your Personal Information in our records. As per the existing legal regulations, specific data fields (such as name, Aadhar number, address etc.) in your Personal Information would be locked in our systems once you enter that information in our Platform. If any part of your Personal Information changes during the course of your engagement with us and your use of our Platform, please use these self-help tools provided by us to update that Personal Information or email us at privacy@multipl.xyz.

    In addition to being able to update and correct your personal data, you may also have other data protection rights, including:

    • The right to withdraw your consent at any time, wherein we have collected and processed your personal data with your consent pursuant to this Privacy Policy. However, you agree that withdrawing your consent will not affect the lawfulness of any processing we carried out before your withdrawal, nor will it affect processing of your Personal Information carried out in reliance on other lawful grounds other than consent. You also agree that in case you do not provide consent or later withdraw your consent, we request you to not access the Platform and/or use the Services. In such a scenario, we also reserve the right to not provide you any Services through the Platform and may delete your information or de-identify it so that it is anonymous and not attributable to you.
    • The right to ask for a copy of your Personal Information in a portable (machine-readable) format.
    • The right to deny us from using your Personal Information for direct marketing other campaigns/programmes.

    The right to make any of the above requests by contacting us at privacy@multipl.xyz. We will respond to all requests in accordance with the applicable laws.

  9. HOW DO YOU DELETE/DEACTIVATE YOUR ACCOUNT?

    Multipl does not sell, trade, or otherwise transfer to outside third parties your Personal Information as the term is defined under the SDPI Rules. Please note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our Services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. Users also have the option to request for an account deactivation instead. This will temporarily block user access to the App and the Platform until they send a re-activation request and successfully re-activate their account.

    To make a request for such disclosure, or identification, deactivation and/or deletion of the Platform account and Personal Information in all our systems that we store on you, please send an email to privacy@multipl.xyz or write to us at Multipl, B6-1102, Elita Promenade, JP Nagar 7th Phase Bangalore 560078.

  10. WILL WE UPDATE THE PRIVACY POLICY?

    We reserve the right, at our sole discretion, to revise, change or modify this Privacy Policy from time to time and such modifications shall be binding on only upon your acceptance. Therefore, we urge you to review the Privacy Policy periodically to ensure that you agree with our latest information on our privacy practices. We will make best efforts to inform you of any amendments by e-mail oy notification in your account on the Platform. However, it is your responsibility to check the Privacy Policy regularly to ensure that you agree with it and your continued use of the Platform will be deemed to be your acceptance of any changes that we make.

  11. TERRITORIAL RESTRICTION

    The App, our Platform, and the Services are only available for use within India. You must comply with this Platform Privacy Policy and Platform Terms of Service. If you are a resident of any other country, you may not use the App, our Platform, and the Services.

  12. COPYRIGHT POLICY

    The contents of this website and the Platform may not be reproduced partially or fully, without due permission from Multipl, as per the Copyright Act, 1957. If referred to as a part of another publication, the source must be appropriately acknowledged. The contents of this website cannot be used in any misleading or objectionable context.

  13. GOVERNING LAW

    This Privacy Policy shall be governed by the law of the republic of India, without respect to its conflicts of laws principles. Each of the parties to this Privacy Policy consents to the exclusive jurisdiction and venue of the courts located in Bangalore, India for any actions not subject to Dispute Resolution and Arbitration provisions as set forth below in XIV ( Dispute Resolution).

  14. DISPUTE RESOLUTION

    Dispute Resolution. Any claim, dispute or difference relating to or arising out of this Terms of Service and Platform Privacy Policy shall be referred to the arbitration, of a sole arbitrator appointed mutually. The arbitration shall be subject to the Arbitration and Conciliation Act, 1996 as may be amended from time to time. The seat and venue of arbitration shall be Bangalore, Karnataka, India. The proceedings shall be undertaken in English. The arbitration award shall be final and binding on the parties.

  15. PRIVACY QUESTIONS AND GRIEVANCE REDRESSAL

    To ask questions or comment about this Privacy Policy and our privacy practices, please contact us at:

    - Privacy Officer: Jagannathan Raghavan
    - Email: jags@multipl.xyz
    - Address: Multipl, B6-1102, Elita Promenade, JP Nagar 7th Phase Bangalore 560078.