PRIVACY POLICY

Axion Tech Systems Pvt. Ltd. (CIN: U72900GJ2021PTC122271) is a company incorporated under the laws of India having its registered office at Block B, Third Floor, Siddhi Vinayak, Tower, Off. S.G. Highway Road, Makarba, Ahmedabad, Gujarat, India, 380051 (hereinafter referred to as Company or we or us).

The Company is engaged in the business of enabling users to make investments in financial instruments offered on the Platform by third party entities by acting as an aggregator or an intermediary (hereinafter referred to as “Services”). In this regard, the Company is operating mobile applications and websites [(name of mobile app) and https://steadyincome.in] (hereinafter referred to as the Platform).

Company recognizes the importance of maintaining the privacy and confidentiality of its users. We are committed to serving you in the best possible manner and we value you as our user/customer/visitor (hereinafter referred to as the user or you or your as the context may require) of our Platform.

In the process of you using the Platform or availing any of the existing and/or future products or services or facilities provided by the Platform, you may be required to furnish information, including Personal Information, Financial Information, Data Usage Information and/or any other information that may be sensitive or proprietary or confidential in nature (hereinafter referred to as Information). You are urged to keep the Information current to ensure that the Services offered by the Platform remain relevant and enable us to reach you.

Provided that any Information that is freely and legally available or accessible in public domain or furnished under any statutory provisions for the time being in force shall not be regarded as sensitive Personal Information or data for the purposes of this Privacy Policy.

Company is purely acting as an aggregator or an intermediary for products and services that are being offered on the Platform by third parties. Under no circumstances is the Company responsible or liable in any manner whatsoever for such products and services that are being offered on the Platform.

Applicability

Please read this Privacy Policy carefully. This Privacy Policy applies to all the users of our Platform. By visiting and/or using our Platform, you agree to the provisions of this Privacy Policy.

This Privacy Policy sets out the way in which we collect, use, disclose, transfer, and store your Information. The contents of the Platform are the properties of Company.

This Privacy Policy is not intended to and does not create any contractual or financial or any other legal rights in favour of any user or any other party. Users are informed that by using the Platform, they are deemed to have consented to the collection and use of Information by the Platform in the manner as stated herein in this Privacy Policy.

This Privacy Policy is published in compliance of the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“the Rules") as amended from time to time and/or such other laws as applicable to Information.

By using the Platform and/or registering yourself at the Platform, you authorize us (including our authorized representatives and business partners) to contact you via email or phone call or WhatsApp or SMS and offer you our Services, impart product knowledge, offer promotional offers running on the Platform and offers by authorized business partners and associated third parties (to the extent permissible), for which reasons your information may be collected in the manner as detailed under this Privacy Policy.

We and our authorized third parties may collect different types of Information, as required under the applicable laws and regulation and also based on your interest in our Services and our business relationship with you.

You are advised to carefully read this Privacy Policy before using the Platform and/or any other platform, application or channels related to the Platform and/or communicating with us and/or while sharing information/data with us. Company shall not be liable / responsible for any breach of privacy owing due to the user’s negligence. Please note that our Platform may contain links to third party/external applications / digital platforms which are provided for your convenience. We are only responsible for the privacy practices and security of our Platform. We recommend that you check the privacy and security policies and procedures of each and every other application / digital platform that you visit.

As a user, you also agree that we may use the Information provided by you to contact you and deliver information that is aimed at targeting your interests, provide updates and communications relevant to your use of the Platform. If you do not want to receive these communications, you may choose to opt-out of the same.

Company shall not be held liable for disclosure of Confidential Information (including any Information) if such disclosure is in accordance with this Privacy Policy, Terms of Use and/or applicable laws. Confidential Information shall mean and include all information, documents and materials whether written or otherwise in any other explicit form, that has been or may hereafter be provided or shown to us or uploaded on the Platform, irrespective of the form of communication. Confidential Information shall include Information as defined hereinabove.

If you object to your information being transferred or used, please do not use the Platform.

1. The information that we collect

A. Information you provide to us

We may ask you to provide us with certain categories of information such as personal information which is information that could reasonably be used to identify you personally (Personal Information) and you hereby consent to the collection of such Personal Information by us. Personal Information that we may collect from you, or about you, may include but is not limited to, the following:

1. Name of the User
2. Date of Birth, mobile number, e-mail address and Gender
3. Residential address
4. KYC Information such as Scanned copies (.pdf or .png or .jpeg or .jpg file) of Aadhaar and PAN, passport, driving licence, Voter’s Identity Card issued by the Election Commission of India, job card issued by NREGA duly signed by an officer of the State Government, or letter issued by the National Population Register containing details of name and address);
5. Financial information (such as Demat Account Details, Client Master, information relating to your bank account details, financial service provider, credit card details, direct transfer details and information relating to the transactions created by you on the Platform (“Financial Information”).
6. Your usage details such as time, frequency, duration and pattern of use, features used and the amount of storage used;
7. Internet protocol (IP) address, browser type, internet service provider (ISP), browser language, referring URL, files accessed, errors generated, time zone, operating system, number of clicks to analyze trends and other visitor details collected in Our log files, the pages of our Platform that you visit, the time and date of your visit, the time spent on those pages and other statistics (“Log Data”); and
8. Any other Information that is willingly shared by you.

We may collect Information through various forms and at various places through the Platform, such as when you first register with us, when you create a transaction with us or through us, when you participate in a survey, provide a testimonial, participate in an interactive feature or forum (such as chat features), contact us or interact with us and/or when you update your information.

B. Information we collect as you access and use our Platform

In addition to any Information that you choose to submit to us, we may use a variety of technologies that automatically (or passively) collect certain information whenever you access the Platform (“Usage Information”). This Usage Information may include the following:

• Activity data, such as when you completed a form on the Platform;
• Information from your visits to this Platform, including the type of browser and operating system you use, access times, pages viewed, URLs clicked on, your IP address, geographical location, browser type and version, operating system
• Pages you visited before and after navigating to this Platform including referral source, length of visit, page views, website navigation paths;
• Social media tracking pixels that allow platforms such as Facebook, Instagram, LinkedIn, Youtube and Twitter to interact with this Platform and give feedback on your actions; and/or
• Device information, including but not limited to the unique device identifier, hardware model, operating system and version and mobile network information or any other.

We may use Usage Information for a variety of purposes including to enhance or otherwise improve features of the Platform and to enhance the quality of our Services.

Your IP address or other unique identifier for your computer, mobile or other device used to access the Platform is referred to as a Device Identifier. A Device Identifier is a number that is automatically assigned to your device used to access the Platform, and our computers identify your device by its Device Identifier. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information or a Device Identifier with your Personal Information, we will treat it as Personal Information.

In addition, tracking information is collected as you navigate through our Platform, including, but not limited to geographic areas.

C. We collect Cookies

A cookie is a piece of data stored on the user's computer tied to information about the user.

To enhance your experience with our Platform, we may use “Cookies”. Cookies are text files that we may place in your computer browser to store your preferences. Cookies are used to record various aspects of your visit and assist us in providing you with uninterrupted service. One of the primary purposes of cookies is to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify the browser setting to decline cookies if you so prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of the Platform that may depend on cookies. If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted. If you choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated.

You should be aware that we cannot control the use of cookies (or the resulting information) by third-parties, and use of third-party cookies is not covered by our Privacy Policy.

D. Information received by us from Third Parties

We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information, joint marketing partners, social media platforms, people with whom you are connected on social media platforms, and other third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to use such of our Services that we believe may be of interest to you.

2. Use of the Personal Information Collected

Our primary goal in collecting your Information is to provide you with an enhanced experience when using the Platform.

The Information that we collect from you is held in accordance with applicable laws and regulations in India. It may be used by us for a number of lawful purposes connected with our business operations and functions.

We will communicate with you using the contact information provided by you in order to respond to any queries that you may have and to provide any information that you may request regarding the Services. We may communicate with you either by written, physical communication, email, telephone, SMS or via notifications on your mobile device.

We may also send strictly service-related announcements to you on rare occasions and when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email, text message, flash notification or telephone call. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to unsubscribe from such emails.

We may use Information collected from you in the following ways:

1. To enable Company to comply with its legal and regulatory obligations and submission of information to the regulatory bodies and authorities.
2. To prevent, discover and investigate violations of this Privacy Policy or the Terms and Conditions, and to investigate fraud or other matters
3. To operate and improve our Platform and tools associated with the it
4. To create aggregated and anonymized information to determine which Platform features are most popular and useful to users, and for other statistical analyses
5. To customize the content or the Services on the Platform for you, or the communications sent to you through the Platform
6. To help provide you the Services
7. To observe, improve and administer the quality of Service
8. To analyze how the Platform is used, diagnose technical problems
9. Remember the basic information provided by you for effective access
10. To confirm your identity in order to determine your eligibility to use the Platform and avail the Services
11. To notify you about any changes to the Platform (if any)
12. For the purpose of sending administrative notices, Service-related alerts and other similar communication with a view to optimizing the efficiency of the Platform
13. Doing market research, troubleshooting, protection against error
14. To reinforce Company’s Terms of Use
15. To investigate and take action against illegal or harmful behaviour of any users of the Platform
16. To address network integrity and security issues
17. For internal purposes such as auditing, data analysis and research to help us deliver and improve our Platform and Services
18. All other general administrative and business purposes

You hereby agree that you authorize us to contact you for the above mentioned purposes even if you have registered yourself under DND or DNC or NCPR service(s). Your authorization, in this regard, shall be valid as long as your account is not deactivated by either you or us.

Information may also be collected and shared with third parties if there is content from the Platform that you specifically and knowingly upload to, share with or transmit to an email recipient, online community, platform, or to the public. This uploaded, shared or transmitted content will also be subject to this Privacy Policy.

We may use your Information solely for the purposes of enabling you to use the Services and for providing you with an enhanced experience when using our Services.

3. How and When Do We Disclose Information to Third Parties?

We may share non Personal Information, such as aggregated user statistics and Log Data, with third parties for industry analysis, demographic profiling, to deliver targeted advertising about other products or services, or for other business purposes. We do not sell, share, rent or trade the Information we have collected about you, including Personal Information, other than as disclosed within this Privacy Policy or at the time you provide your Information. We do not share your Personal Information with third parties for third parties’ direct marketing purposes unless you consent to such sharing at the time you provide your Personal Information. Further, we will also not disclose your Personal Information with any affiliated or unaffiliated third parties, except as mentioned above and also to: provide you the Services and for generation of reports with regard to such transactions, conform with any legal requirements or comply with legal process (es), enforce the terms and conditions of the products or services and protect the interests of the Company, its subsidiaries, affiliates and/or its members, directors, officers and representatives.

We may share the Information collected from you with third parties such as payment gateways, entities including those financial institutions whose instruments you have invested in or with such third party with whom we are required to share the Information under a requirement of law or for the purpose of providing you the Services. We shall endeavor that a third party with whom any part of your Information including Personal Information, Usage Information and/or Financial Information is shared has and is implementing adequate and reasonable security measures for the protection of your Information. Such Information shall be used/shared/maintained/accessed/stored with/by third party technology service provider/RTAs/authorized service providers in order to enable/ facilitate/ complete/ process the online transactions and report/statement generation.

A. When You Agree to Receive Information from Third Parties

You may be presented with an opportunity to receive information and/or marketing offers directly from third parties with whom you have created a transaction through the Platform. If you do agree to have your Information shared, your Information will be disclosed to such third parties and all Information you disclose will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive any kind of communication from a third party, you will need to contact that third party directly.

B. Administrative and Legal Reasons

We will at all times cooperate with the Government and law enforcement officials and private parties to enforce and comply with the applicable laws. Thus, we may access, use, store, transfer and disclose your Information including disclosure to third parties such as Government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, governmental requests or legal process; (ii) to protect the safety, rights, property or security of the Company, our Services, the Platform or any third party; (iii) to protect the safety of the public for any reason; (iv) to detect, prevent or otherwise address fraud, security or technical issues; and /or (v) to prevent or stop any activity we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Further, we may use the IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as internet third party service providers, wireless third-party service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion. Such disclosures may be carried out without notice to you.

C. Business Transfer

We may share your Information (including your Personal Information, Financial Information and Usage Information) with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such Information: (i) to a subsequent owner, co-owner or operator of the Platform or applicable database or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.

D. Consulting

Company may partner with third parties to provide specific Services if required. When you sign-up for the Services, Company will share names, or other Information such as email address or contact details that is necessary for a third party to provide these Services. Company’s contractual arrangements with such third parties, restrict these parties from using personally identifiable information except for the explicit purpose of assisting in the provision of these Services.

E. Exclusion

This Privacy Policy does not apply to any information other than the Information collected by Company through the Platform. This Privacy Policy will not apply to any unsolicited information provided by you through this Platform or through any other means. This includes, but is not limited to, information posted on any public areas of the Platform. All such unsolicited information shall be deemed to be non-confidential and Company shall be free to use, disclose such unsolicited information without limitation.

Company also endeavors to protect your Information off-line other than as specifically mentioned in this Privacy Policy. Access to your Information is limited to employees, agents or partners and third parties, who Company reasonably believes will need that Information to enable Company to provide the Services to you through the Platform. However, Company is not responsible for the confidentiality, security or distribution of your own Information by our partners and third parties outside the scope of our agreement with such partners and third parties.

F. Data Retention

Your Information will be retained with Company as long as your account is active or as needed to provide Services to you and in any event with Company for a minimum period of 10 (ten) years. If you wish to cancel your account or request that Company no longer uses your Information to provide Services, you may contact Company at hello@steadyincome.in. Company will retain and use your Information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements or for other business purposes. Any Information collected from you and shared with third parties for provision of Services to you may be stored by such third parties indefinitely. In the event that you wish for your Information to be destroyed, please contact Company at info@steadyincome.in . While we will communicate your message to the third party with whom the data has been shared, we cannot guarantee that the data will be destroyed or deleted from the servers of the third party.

 

4. Third Party Content and Links to Third Party Services

The Platform contains content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when web pages from any online or mobile services are provided to your browser. In addition, when you are using the Platform, you may be directed to other websites or platforms that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. These other websites or platforms may send their own cookies to you, independently collect data or solicit Information and may or may not have such third party published privacy policies. When you leave our Platform, we encourage you to read the privacy statements of all third-party platforms or websites before submitting any information to such third parties.

 

5. Change of Information and Cancellation of Account

You are responsible for maintaining the accuracy of the Information you submit to us, such as your contact information provided as part of your account registration process. If your Personal Information changes, or if you no longer desire to access the Platform, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through hello@steadyincome.in . We will make good faith efforts to make the requested changes in our then active databases as soon as reasonably practicable.

You may also cancel or modify your communications that you have elected to receive from the Platform by logging into your user account and changing your communication preferences.

If you wish to cancel your account or request that we no longer use your Information to provide you details with respect to our Services and the Platform, please write to us at hello@steadyincome.in .

 

6. Opt-Out

If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Platform and the Services, please send Company an email at hello@steadyincome.in.

7. Security

Information including Personal Information, Financial Information and Usage Information that we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your Information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that Information you supply will not be intercepted while being transmitted to us over the Internet or wireless communication and any Information you transmit to Company you do at your own risk. If, despite our best efforts, an unauthorized breach of our security measures occurs, resulting in the unauthorized access, duplication, removal or alteration of any Information including Personal Information, Financial Information, third party information, Usage Information and/or device related Information then, Company, its members, directors, officers, employees, promoters, and/or affiliates will not be held responsible or liable for any loss or damages or costs and expenses resulting from such breach.

8. Changes to The Privacy Policy

From time to time, we may amend, revise and/or update this Privacy Policy to reflect changes to our information practices. Any changes will be effective immediately upon the posting of the revised Privacy Policy. If we make any material changes, we may notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Platform prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Your legal rights to information, rectification, blocking, erasure, and objection are not affected by these changes.

9. Grievance Redressal

In case you have any grievances with respect to this Privacy Policy, then please send an email to grievance@steadyincome.in

10. Social Media & DND

Company may maintain/ upload information on social media sites like Facebook, Instagram and Twitter. When you visit the social media properties/ account of Company, we collect information about your activities on those properties. The information we review includes whether you visited or commented on a blog or provided a rating or made comment etc.

In furtherance to your usage of the Platform, you expressly waive the Do Not Call (DNC) / Do Not Disturb (DND) registrations on your phone/mobile numbers for contacting you. Hence, there is no DNC / DND check required for the number you have provided/ made available to Company. Modes of contacting you/ communication may include sending SMSs, WhatsApp, email alerts and / or telephonic calls etc.

You as the user unconditionally authorize Company, its affiliates, vendors, service providers, facilitating agency and their representatives to call, send email, SMS or communicate with you through WhatsApp about the Services and other updates/ offering from time to time.

11. Intellectual Property

The Platform and the contents contain copyrights, patents and other proprietary materials that are owned by Company, its affiliates and/or third parties and are protected by intellectual property laws of the country.

You should assume that all content of the Platform is copyrighted or protected unless otherwise noted and may not be - used, copied, reproduced, downloaded, modified, published, distributed, transmitted, or exploited, in whole or in part, in any form or by any means, except as provided herein and not without the express written permission of Company or the original creator of the material.

Product names, logos, trademarks, and service marks that are used or displayed on the Platform (collectively, the “Trademarks”) are registered or unregistered trademarks and the exclusive property of Company or its affiliates or such third parties acting through Company. No use of the Trademarks may be made without Company’s prior written authorization, except to identify the Services of Company. Other product names, logos, trademarks, and service marks appearing on the Platform that are not owned by Company may not be used without express permission from its owner.

Nothing contained herein shall be construed as conferring any license or right, either express or implied, under any intellectual property of Company or any third party.

12. Contact Us

If you have questions, concerns, or suggestions regarding our Privacy Policy, we can be reached using the contact information on our Contact Us page or at Block B, Third Floor, Siddhi Vinayak, Tower, Off. S.G. Highway Road, Makarba, Ahmedabad, Gujarat, India, 380051

info@steadyincome.in

We shall use our best endeavors to acknowledge your questions, concerns or suggestions and dispose of the same at the earliest.