Gullak Money Application is developed by Finterscale Technologies Private Limited, a company incorporated under the Companies Act, 2013 with its registered office at 4th Floor, Building, 387, Koramangala 4th Block, Koramangala, Bengaluru, Karnataka 560034, India. This policy describes how Gullak and its Affiliates/Entities/Subsidiaries/Associates including but not limited to Finterscale Technology Private Limited, (collectively Gullak, we, our, us as the context may require) collect, store, use and otherwise process your Personal Information through Gullak website, Gullak Application, sdk, chatbot, notifications or any other medium used by Gullak to provide its services to you (hereinafter referred to as the Platform). By downloading and using Gullak services, visiting the Gullak website, providing your information or availing our product/services, you expressly agree to be bound by this Privacy Policy and the applicable service/product terms and conditions. We value the trust you place in us and respect your privacy, maintaining the highest standards for secure transactions and protection of your personal information.
This privacy policy is published and shall be construed in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under the Information Technology Act, 2000; that require publishing of the privacy policy for collection, use, storage, transfer, disclosure of Personal Information (means and includes all information that can be linked to a specific individual) including Sensitive Personal Information (all Personal Information which requires heightened data protection measures due to its sensitive and personal nature) (both, hereinafter referred to as Personal Information), excluding any information that is freely available or accessible in public domain. Please note, we do not offer any product/service under our Platform outside India. If you do not agree with this privacy policy, please do not use or access our Platform.
Information Collection
We may collect your Personal Information when you use our services or Platform or otherwise interact with us during the course of our relationship. We collect Personal Information which is relevant and absolutely necessary for providing the services requested by you and to continually improve the Gullak Platform.
Personal and Sensitive Personal Information collected includes but not limited to:
1) name, age, gender, photo, address, phone number, e-mail id, your contacts and nominee details
2) PAN card number, KYC related information such as videos or other online/ offline verification documents as mandated by relevant regulatory authorities, your business-related information
3) OTP sent to you by your bank or via Gullak or any third party Payment gateway
4)balance, transaction history and value, bank account details, wallet balance, investment details and transactions, service or transaction related communication, part of your card details for smooth transaction using Gullak or any of the services
5) your device details such as device identifier, internet bandwidth, mobile device model, browser plug-ins, and cookies or similar technologies that may identify your browser/Gullak Application and plug-ins, and time spent, IP address and location
We and our service providers or business partners may also collect your Personal Information from third parties or information made publicly available including financial history and other information for the purpose of verifying and authenticating an investment transaction request you place with us. This is done in order to prevent suspicious transactions, or to comply with court judgements and bankruptcies, from credit reference and fraud prevention agencies. Additionally, we and our service providers or business partners may also collect vehicle-related information when you opt for vehicle insurance. In case of employment opportunities with Gullak, we and our service providers or business partners may also collect your resume, your past employment and educational qualification for background checks and verifications, through online or offline databases that are otherwise legitimately obtained and are subject to the third party`'`s terms of use and/or privacy statement.
Information may be collected at various stages of your usage of the Gullak Platform such as:
1) visiting Gullak Platform
2) registering on Gullak Platform as an user or any other relationship that may be governed by terms and conditions listed on Gullak Platform
3) transacting or attempting to transact on Gullak Platform
4) accessing links, e-mails, chat conversations, feedbacks, notifications sent or owned by Gullak Platform and if you opt to participate in our occasional surveys
5) otherwise dealing with any of the Gullak Affiliates/Entities/Business Partners/Associates
6) while applying for career opportunities with Gullak
Purpose and Use of Personal Information
Gullak may process your Personal Information for the following purposes:
1) creation of your account and verification of your identity and access privileges
2) provide you access to the products and services being offered by us, merchants, affiliates, subsidiaries, associates, or business partners
3) to conduct the KYC compliance process as a mandatory prerequisite as per the requirements of various regulatory bodies
4) to validate, process and/or share your KYC information, nominee details with other intermediaries, Business Partners or AMCs or financial institutions or with any other service providers as may be required
5) to provide payment instructions; communicate with you for your queries, transactions, and/or any other regulatory requirement, etc.
6)to authenticate a transaction request; validate a standing instruction for a Systematic Investment Plan or confirm a payment made via the services
7) enhancing your user experience in various processes/submission of applications/avail of product/service offerings by analysing user behaviour on an aggregated basis;
8)to monitor and review products/services from time to time; customize the services to make your experience safer and easier, and conducting audits
9)to allow third parties to contact you for products and services availed/requested by you on Gullak Platform or third-party links
10) to carry credit checks, screenings or due diligence checks as lawfully if required by us; detect and protect us against error, fraud, money laundering and other criminal activity; enforce our terms and conditions
11) to inform you about online and offline offers, products, services, and updates; customizing and improving your experience by marketing, presenting advertising, and offering tailored products and offers
12) to resolve disputes; troubleshoot problems; technical support and fixing bugs; help promote a safe service
13) to identify security breaches and attacks; investigating, preventing, and taking action on illegal or suspected fraud or money laundering activities and conducting forensic audits as part of internal or external audit or government agencies located within
14) While we may also process your Personal Information for other legitimate business cases, we ensure to take appropriate steps to minimize the processing to the extent possible, making it less intrusive to your privacy.
Cookies or Similar Technologies
We use data collection devices such as cookies or similar technologies on certain pages of the Platform to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. Cookies are small files placed on your device hard-drive/storage that assist us in providing our services. Cookies do not contain any of your Personal Information. We offer certain features that are only available through the use of a cookie or similar technologies. We also use cookies to allow you to enter your password less frequently during a session. Cookies or similar technologies can also help us provide information that is targeted to your interests. Most cookies are session cookies, meaning that they are automatically deleted from your device hard-drive/storage at the end of a session. You are always free to decline/delete our cookies or similar technologies if your browser/device permits, although in that case you may not be able to use certain features on the Platform and you may be required to re-enter your password more frequently during a session. Additionally, you may encounter cookies or other similar technologies on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by third parties.
Information Sharing and Disclosures
Your Personal Information is shared as allowed under applicable laws, after following due diligence, assessing the recipient`'`s privacy policies and practices, and in line with the purposes set out in this policy. Personal Information is shared only after a contractual obligation is imposed on the recipients to adhere to similar or no less stringent privacy practices of Gullak
We may share your Personal Information in the course of your transaction with different categories of recipients such as business partners, service providers, associates, subsidiaries, legally recognized authorities, regulatory bodies, financial institutions, internal teams such as marketing, security, investigation team etc.
Personal Information will be shared, as applicable, on need-to-know basis, for the following purposes:
1) for enabling the provision of the products/services availed by you and facilitating the services between you and the service provider, as requested
2) for complying with applicable laws as well as meeting the Know Your Customer (KYC) requirements as mandated by various regulatory bodies, whose regulated service/product you opt through our services/Platforms
3) for completing a transaction initiated by you on a Business Partner site, where based on your instructions, the partners requests to fetch your Personal Information from us
4) for the purpose of processing your financial product subscription requests placed with us and ensuring that these requests reach the relevant financial institution whose service/product you have opted for
5) if it is required by financial institutions to verify, mitigate or prevent fraud or to manage risk or recover funds in accordance with applicable laws/regulations
6) for services related to communication, marketing, data and information storage, transmission, security, analytics, fraud detection, risk assessment and research
7)enforce our Terms or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public
8) if required to do so by law or in good faith we believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process
While the information is shared, Gullak ensures that the processing is carried out only on behalf of Gullak and this policy is applicable to the extent possible.
Storage and Retention
To the extent applicable, we store Personal Information within India and retain it in accordance with applicable laws and for a period no longer than it is required for the purpose for which it was collected. However, we may retain Personal Information related to you if we believe it may be necessary to prevent fraud or future abuse or if required by law such as in the event of the pendency of any legal/regulatory proceeding or receipt of any legal and/or regulatory direction to that effect or for other legitimate purposes.
Once the Personal Information has reached its retention period, it shall be deleted in compliance with Gullak`'`s policy on retention and data deletion.
Reasonable Security Practices
We understand that as effective as our security measures are, no security system is impenetrable. Hence, as part of our reasonable security practices, we undergo strict internal and external reviews to ensure appropriate information security encryption or controls are placed for both data in motion and data at rest within our network and servers respectively. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited.
Third-Party Products, Services, or Websites
When you are availing products and services of service providers on Gullak Platform, Personal Information may be collected by respective service providers and such Personal Information shall be governed by their privacy policy. You may refer to their privacy policy and terms of service to understand how your Personal Information will be handled by such service providers.
Our services may include links to other websites or applications when you visit our Platform. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser or on the m-site you are redirected), use of any Personal Information that you provide on these websites or applications is governed by the privacy policy of the operator of the application/website, you are visiting. That policy may differ from ours and you are requested to review those policies or seek access to the policies from the domain owner before proceeding to use those applications or websites. We do not accept any responsibility or liability for usage of your Personal Information by these third parties or their policies.
Your Consent
We process your Personal Information with consent. By using our Platform or services and/or by providing your Personal Information, you consent to the processing of your Personal Information by Gullak in accordance with this Privacy Policy. If you disclose to us any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.
Children Information
We do not knowingly solicit or collect Personal Information from children under the age of 18 and use of our Platform is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are under the age of 18 years then you must use the Platform or services under the supervision of your parent, legal guardian, or any responsible adult.
Changes to Policy
Since our business changes constantly, so will our policies. We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time without any prior written notice to you. We may, however, reasonably endeavour to notify you of the changes, it is your responsibility to review the Privacy Policy periodically for updates/changes. Your continued use of our services/Platform, following the posting of changes will mean that you accept and agree to the revisions. We will never make changes to policies in order to make it less protective of Personal Information already shared by you.
Grievance Officer
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 of this Officer have been provided below:
Name: Manthan Shah
Email: support@gullak.money
Contact Us
In case you have any questions or concerns regarding the processing of your Personal Information or this Privacy Policy you may write to us at support@gullak.money.