, includes (i) Dezerv Investment Private Limited (“DIPL”
) a private limited company incorporated under the Companies Act, 2013 (CIN U65999MH2021PTC358833); (ii) Dezerv Distribution Services Private Limited, ("DDSPL"
) a private limited company incorporated under the Companies Act, 2013 (CIN U67190MH2022PTC385467); and (iii) includes all present and future Affiliates of DIPL and DDSPL respectively. The term “Affiliate”
means with respect to an entity, the holding company, subsidiaries and associate companies and shall include any other entity, individual, firm, or corporation, directly or indirectly, through one or more intermediaries, controlling, controlled by, or under common control with such entity.
Dezerv Investments Private Limited and/or its affiliates ( “Dezerv”/ “Company”/ “We”/ “Our”/ “Us”
) may become privy to some Personal Information ( defined below
) provided by individuals ( “Users”/ “You”/”Your”
), including information which may or may not be of confidential nature. We value Your privacy and recognises the importance of maintaining the privacy of Your Personal Information and appreciate Your trust in Us.
), Personal Information shall mean any information provided by You and/or available with the Company, which helps the Company identify You. However, no such information which is already available in public domain, or which can be furnished under Right to Information Act, 2005 or any law in force in India shall be considered as Personal Information under this Policy ( “Personal Information”
This Policy will help You understand the types of information we collect from You through Promotional Material (defined below) and/or the website, https://www.dezerv.in
(hereinafter referred as “Platform”
), which are owned, operated and maintained by Dezerv; the purpose for which the information is collected; how the information is used; the intended recipients of such information; and how the information is protected. If You would like more details, please contact Us at email@example.com
of the Platform and shall be read harmoniously and in conjunction with the Terms. This Policy applies to all the information including Personal Information collected by Us. 1. Collection of InformationI. Information You voluntarily submit
We collect Personal Information from You when You voluntarily provide such information, such as when You contact Us with inquiries, register for access to the Platform or purchase products or Services from the Platform.a. Using Dezerv Platform as a Visitor
Every time You visit / access / use Our Platform, We collect certain information about Your interaction with Our Platform, such as pages visited and average time spent on the Platform, Your internet protocol address, the unique identifier of Your device and device information such as operating system, operating system version, browser plugins, cache, system activity, hardware settings, date and time of Your request and referral URL, and cookies that may uniquely identify Your browser, browser data, mobile application and mobile information.b. Interaction with Dezerv’s Promotional Material
We collect information which You may provide while interacting with Our promotional material which includes but not limited to promotional emails, newsletters and advertising material ( “Promotional Material”
). This information includes the number of clicks, time spent viewing the links from the Promotional Materials, Your Personal Information, etc.c. Using Dezerv as a Registered User
i. To complete your profile assessment, we may ask You questions (quiz) related to your age, investing experience, risk appetite for investments etc.
ii. We shall collect Your Personal Information such as first name, last name, current contact and address details, email address, password, date of birth, signature, PAN, demat details, place of birth, city, country, complete address, pin code along with information regarding whether you are Politically Exposed Person (PEP) for the purpose of money laundering act and PMLA for The Foreign Account Tax Compliance Act (FATCA), your annual income/net worth, billing information, and ask to access Your LinkedIn profile link, Facebook link, Twitter link and Google account.
iii. We may also ask for additional information in order to use certain features of the Services.
iv. We also collect technical data about Your interaction with the Services. The technical data includes but is not limited to Your internet protocol address, the unique identifier of Your device and device information such as operating system, operating system version, browser plugins, cache, system activity, hardware settings, date and time of Your request and referral URL, and cookies that may uniquely identify Your browser, browser data, mobile application and mobile device information.
v. We also collect Your IP address.
Our legal basis for processing this information is Your consent, and by voluntarily providing Us with Personal Information, You are consenting to Our use of it in accordance with this Policy. If you provide Personal Information to Us, You acknowledge and agree that such Personal Information may be transferred and stored from Your current location to the offices and servers of Dezerv and the authorized third-parties referenced below.
Dezerv shall not be liable for the authenticity/misrepresentation/fraud/negligence for the information provided by You. The Company shall also not be responsible for verifying any information provided by You. The sole liability for any misrepresentation/fraud/negligence/ any other criminal or civil liability emanating from the information provided by You shall be Your responsibility.II. Information We Collect from Others:
We may receive information about You from other sources such as when You use a third-party software through the Platform, they may transfer information to Us for fulfilment of their obligations under agreement between such third-party and Us. For more information about our use of third-party providers, please see further below.III. Information We Collect within the Dezerv Group:
We may receive information about You from an entity in the Dezerv Group when You use the Services offered by such entity through the Platform. Such entity within the Dezerv Group may transfer the information to Us for providing relevant Services and for fulfilment of their obligations under agreement, if any, between the entities within the Dezerv Group.IV. Automatically-Collected Information:
We automatically collect certain information about You and the device with which You access the Platform such as Your IP address, operating system type, browser type, referring website, pages You viewed, mobile application, mobile device information and the dates/times when You accessed the Platform. We may also collect information about actions You take when using the Platform, such as links clicked.V. Cookies:
We may log information using cookies, which are small data files stored on your browser by Dezerv. We may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on Your browser until deleted, to provide You with a more personalized experience on the Platform.2. Use of Your Information
We use all the collected data to:
a. respond to Your queries about the Services;
b. send communications relevant to Your use of the Services;
c. offer You products or Services that We believe may be of interest to You;
d. 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;
e. to send You Promotional Material, 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, Your account on the Platform and information on the use of the Platform;
f. ensure security on the Platform and detect any errors, fraud and other criminal or otherwise prohibited activity on the Platform;
g. aggregate the anonymised information from registered Users to perform market research, project planning, product development, troubleshoot problems, analyse User behaviour, marketing purposes, and promotions;
h. identify and use Your IP address to help diagnose problems with Our server, resolve such problems and administer the Platform. Your IP address may also be used to help Us identify You and to gather broad demographic information;
i. be compliant with Foreign Account Tax Compliant Act (FATCA) and other applicable laws;
k. use Your information to verify Your identity in the event You contact Us for assistance of Our Services. We use cloud-based software tools to perform certain business-related functions. Examples of such functions include, maintaining databases and servers, processing text messages, phone calls, chats and emails, and marketing and sales analytics.3. Connecting Your email/LinkedIn account
Dezerv will seek Your consent to connect/integrate Your email account(s)/LinkedIn account/Facebook account/Twitter account/Google account with Your account on the Platform by clicking on the authentication email sent by Us on Your registered email address or by seeking permission on Your LinkedIn account/Facebook account/Twitter account/Google account. We request You to review the information prior to giving Your consent for integration of the email addresses/LinkedIn account/Facebook account/Twitter account/Google account with the account on the Platform.
Once connected, the Platform will securely access and curate specific financial/investment/ other products and Services for You based on Your Financial transactions, investments and past financial behaviour. You may at any time opt to de-link Your email addresses and LinkedIn account connected with the account on the Platform, by managing these connections with the options provided on the Platform. Such de-linking can also be achieved by reviewing permissions on the email account or linked-in account.4. Links to Other Third – Party platforms and collection of information
Dezerv may link You to other third-party platform that may collect Your Personal Information such as Your IP address, browser specification, or operating system.
Dezerv uses third-party web analytics service providers such as Google Analytics, Clevertap, Hotjar and Clearbit. These web analytics services aggregate Personal Information, geographical data and other cookies based data. We use this information to identify the most popular areas of the Services and how to best present and customise them. We may use the unique identifier of Your device for security purposes to track suspicious activity. For instance, if We detect that Your Dezerv account is being accessed from multiple devices, We may contact You to ensure that You have authorised such access. You consent to process the information provided by You including Personal Information through third party web analytics service providers in accordance with this Policy.6. Access and Update Your Personal Information
If You want to review your Personal Information or believe that the Personal Information provided by You on the Platform or through Promotional Material is inaccurate or not up to date or have any questions about the accuracy or safety of Your Personal Information, please do contact Us at firstname.lastname@example.org
.7. Disclosure of Information
Except as provided in this Policy, Dezerv will not transfer, sell or rent Personal Information collected to anyone, for any reason, at any time. Dezerv shall also ensure reasonable care and prevention of any unauthorised disclosure of Your sensitive Personal Information. Dezerv will share Your information with judicial, administrative and regulatory entities to comply with any legal and regulatory requirements under applicable laws.8. Payment Information:
You may provide payment information when You use the Platform to avail Our Services such as debit card numbers, billing information using third-party intermediary PCI-DSS compliant service providers. The payment information is provided directly by You, via the Platform, into the PCI/DSS-compliant payment processing service to which Dezerv subscribes, and Dezerv does not, itself, process or store the payment information. Further, these intermediaries are not permitted to store, retain, or use Your billing information for any purpose except for payment processing on Our behalf.9. Retention of Personal Information
Dezerv may collect and/or store Personal Information of persons under the age of 18 years ( "Minors"
) that their parent or guardian under applicable laws, provide on the Platform to avail the Services. While providing Personal Information of the any Minor, the parent or guardian under applicable law, gives consent to Dezerv, to store / use such Personal Information of Minors as per the Policy.11. Customer Care
If You have any complaints or queries regarding Your Personal Information or the Policy, please contact:
Name - Neil Mendonca
Email - email@example.com. Deletion
In the event that Your Personal Information is deleted from Our servers due to application of law, withdrawal of Your consent or due to any other reason, You agree that You will not access any or all Our Platforms or Services.13. Security Practices and Procedures
Our Platform has stringent security measures in place to protect the loss, misuse, and alteration of the information under Our control. Whenever You as a Registered User change or access Your account information, We offer the use of a secure server. Once your information is in Our possession We adhere to strict security guidelines, protecting it against unauthorized access. We are in compliance with privacy laws of India and are not bound by privacy laws of any jurisdiction other than India.
Dezerv follows industry best practices, using open and known principles when transferring and storing Your data. All the User data is stored securely on Amazon Web services (AWS) cloud. However, Dezerv cannot guarantee absolute security as no security measure can provide 100 % security of the information transmitted on internet or electronically stored on servers.
We also train and require Our employees to safeguard Your information. We also use physical, electronic and procedural safeguards and provide access to Personal Information only to employees, agents and/ or Affiliates on a need to know basis.
We assume no liability for any disclosure of information due to errors in transmission, unauthorised third-party access to Our Platform and data bases or other acts of third-parties, or acts or omissions beyond Our reasonable control and You shall not be entitled to hold Dezerv responsible for any breach of security. In the event Dezerv becomes aware of any security breach, it will notify You as soon as possible and take appropriate action to the best of its ability to remedy such a breach.
If You think that the security of Your Dezerv account has been compromised, You shall change Your password and contact Us immediately for further assistance.14. Use of Google API server data
Dezerv’s use of information received from Google APIs will adhere to Google API Services User Data Policy
, including the Limited Use requirements.15. How Your Information is Transmitted and Stored
Your information including Personal Information is transmitted between Your device and Our servers using HTTPS protocol for encryption. HTTPS is the technology used to create secure connections for Your web browser and is indicated by a padlock icon in Your browser. In addition to HTTPS, We make sure that Your Personal Information is always encrypted or hashed before We store it. We use industry standard encryption and hashing algorithms.16. Consent Withdrawal
If You wish to withdraw Your consent given under this Policy for collection and use of any Personal Information, You can withdraw Your consent by sending Us an email at firstname.lastname@example.org
.17. Grievance Officer
In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Mr. Neil Mendonca
Email: email@example.com. Legal Obligation and Jurisdiction
Dezerv is bound by the (Indian) Information Technology Act, 2000 and rules made thereunder, and it shall comply with all its provisions. Under Section 43A of the (Indian) Information Technology Act, 2000, Dezerv and all its vendors are obliged to maintain reasonable security procedures to safeguard Your data.
Any disputes arising under this Policy shall be governed by the laws of India.19. Updates to this Policy
This Policy was last updated on November 3, 2022 ("Last Update Date"). From time to time We may change Our Policy. We will notify You of any material changes to this Policy as required by law. We will also post an updated copy of the Policy on Our Platform. Please check Our Platform periodically for updates on the Policy. Changes to this Policy will be effective as of the stated Last Update Date mentioned in the Policy. By continuing using the Platform i.e. by providing information on the Platform / browse the Platform / access the Platform / use the Services provided by the Company on the Platform, after any change in this Policy, You agree with the modified and updated Policy and provide consent to the collection of information including Personal Information disclosed by You on the Platform according to terms of such modified Policy.