Privacy Policy

Last updated: January 30, 2021

INTRODUCTION

Finteller Advisors Private Limited ("Goalteller" , "we" , "us" , "our" or "Company") is a fintech company providing financial solutions and services to users through our Platform, as described in our terms of service (“Terms of Service”).

We at Goalteller 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 website and mobile app, respectively (collectively referred to as the “Platform”) and our Services (defined below) through our Platform, which shall be incorporated into and subject to the Terms of Service of the Platform and shall be read harmoniously and in conjunction.

The Platform and related Services are primarily available for use and download within India only.

We strictly adhere to the requirements of the data protection law 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 (as may be amended).

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it.

The Platform caters to individual end-users for their personal use only and not for commercial purposes. The Platform allows you to build your own financial plan (retirement planning, investment planning and goal planning among other categories) purely based on the information provided by you on the Platform. You may utilise the functionalities made available by us to build your plan. We use a combination of cutting-edge technology and common sense, that guides you at every step of your journey, during and even after your lifetime. All results generated by the Platform is made available on as-is and available basis based on the information you provide us (“Services”).

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.

You may sign-up and login by connecting your account with certain third-party networks like Facebook or Gmail, for example (each a “Linked Network”). If you elect to sign up through or connect a Linked Network, we receive certain profile and account information about you from the Linked Network. The specific information provided by Linked Networks is determined by you and these third parties and may vary by network. In all cases, the permissions page for the Linked Network will describe the information being shared. You should consult their respective privacy policies for information about their practices.

If you have any questions regarding this Privacy Policy, please send us an email at support@goalteller.com

WHAT INFORMATION DO WE COLLECT?

We collect 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, Consolidated Account Statement (CAS) or any other file upload to our Platform when you interact with Goalteller. We will retrieve your financial information, as may be required by us and permitted by RBI from time to time, through the CAMS financial information aggregation functionality, only upon consent provided by you.

This Privacy Policy applies to:

• Information that (i) you may provide to us voluntarily while registering on our Platform for using our Services, and (ii) we are retrieving from third-party government agencies, including but not limited to your, mobile number, email address, password, date of birth, gender, Permanent Account Number (PAN), Aadhar details, e-KYC through UIDAI, CKYC through CERSAI, credit score and liabilities information from credit aggregation portals such as CRIF, income/salary information, risk profile, financial and investment advice (written as well as oral), 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 or other standing instructions to process payments for the Services (“Personal Information”). You can, if required, upload your CAMS or Karvy’s account statement to our Platform to populate, and track your investment history and portfolio details.
• 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 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 third-party APIs will adhere to its respective data policy, which includes, Google OAuth (governed by the Google API Terms of Service and the Google API Services User Data Policy) and Facebook Authentication (governed by the Facebook Platform Terms), including the Limited Use requirements.

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 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, 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 Fees from you in relation to the Services;
• To inform you about online and offline offers, 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 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 (if applicable); and
• For any other purpose, for which you have granted access to such information to us, based on your interaction with Platform

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

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”). 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 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 Messages 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.

TO WHOM DO WE DISCLOSE YOUR INFORMATION?

We will share your Personal Information and Non-Personal Information,

1. with (i) competent legal / statutory / regulatory agencies / authorities, or (ii) partners / service providers acting on our behalf (as the case may be) to the extent necessary, in the following cases:
   • To enable the delivery of the Services availed by you, strictly on a “need to know” basis, in the ordinary course of business, and subject to applicable laws;
   • To protect the rights, property and safety of the Goalteller, our business and Services, partners, service providers and the users, including to enforce the Terms of Service;
   • When directed by or required by legal / regulatory / statutory / governmental authorities under applicable laws and to respond to lawful requests and due legal process; or
   • When required by financial institutions to verify, mitigate or prevent fraud or to manage risk or recover funds in accordance with applicable laws.
2. in case of a corporate sale, merger, acquisition, sale of business, reorganization, dissolution, insolvency, or such similar events, on an aggregate basis

Please note that we will not rent, lease and sell any information to third parties, without your consent.

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.

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.

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 in accordance with applicable laws, after you cancel/ deactivate/ unsubscribe your account with us, as a part of 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.

HOW DO WE SECURE YOUR DATA?

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 including the implementation of access controls, implementation of firewalls, security and penetration tests, secure servers, network intrusion detection and use of anti-virus and anti-malware software.

Please note that no system is completely secure and so while we strive to protect your Personal Information and Non-Personal Information, we cannot guarantee that unauthorized access, hacking, data loss or a data breach of our security measures will never occur. It is further clarified that you have and 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 standards, at your end and on your behalf, to preserve the integrity and security of your information, including but not limited to, the Personal Information and Non-Personal Information provided by you.

You also expressly consent and agree to the sharing of yours Personal Information and payment related information, to the extent necessary, with third-party service providers, including payment gateways and payment processors, to process and manage your payment related information. Such payment information while transmitted through our Platform, shall be secured with industry-standard encryption technology offered by the third-party service providers. The Company cannot guarantee that transmissions of your payment related information or Personal Information will always be secure or that unauthorized third parties will not be able to overcome the security measures taken by the Company or the third-party service providers. The Company thus assumes no responsibility or liability for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control.

HOW DO YOU UPDATE YOUR PERSONAL DATA?

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.

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 atsupport@goalteller.com. We will respond to all requests in accordance with the applicable laws.

WILL WE CHANGE 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 mak

COPYRIGHT POLICY

The contents of this website and the Platform may not be reproduced partially or fully, without due permission from Goalteller, 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.

GOVERNING LAW & DISPUTE RESOLUTION

Any Dispute that may arise in respect of your use (directly or indirectly) of our Platform shall be governed by all laws applicable within the territory of India. You consent and agree that any and all disputes with respect to this Privacy Policy, our Services, and the Platform (collectively “Disputes,” shall be resolved through mandatory, binding arbitration, which shall be governed under the Indian Arbitration and Conciliation Act, 1996. As such, you agree to waive your respective right to have any and all Disputes arising from or related to this Privacy Policy, and/or your use of our Services or Platform, resolved in a competent court. Instead, you and we agree to arbitrate Disputes through binding arbitration (which is the referral of a Dispute to one or more persons charged with reviewing the Dispute and making a final and binding determination to resolve it instead of having the Dispute decided by a judge in court). We agree that the seat of jurisdiction of such arbitration for the Dispute will be held in Bangalore, India.

PRIVACY QUESTIONS AND GRIEVANCE REDRESSAL

If you have any questions, concerns, or suggestions regarding our Privacy Policy, please reach out to us using the contact information on our “Contact Us” page or at support@goalteller.com. If you have any grievance or complaint with respect to the Platform, please reach out to the grievance officer, the name and contact details provided below:

Name: Udit Garg E-mail: support@goalteller.com

We will acknowledge your complaint within a period of 36 (thirty) hours and share the complaint registration number to enable you to track the status of the complaint for future correspondence. The grievance office shall investigate the complaint and shall remove any violative content, if any, and shall resolve the matter within a period of 1 (one) month. The grievance officer shall provide you with a summary of the resolution of the compliant after this process.