Effective as of 01 January 2022
Legal Notice: This website is an information only website of Elever Investment Adviser Private Limited, a private limited company incorporated under the Companies Act, 2013 having its office at 301/302, Third Floor Saket, Callipolis, Surajpur Main Road, Doddakannelli, Bengaluru – 560035, that features the offerings for various Elever products/services and allow users to register and subscribe to robo-advisory services offered by Elever Investment Adviser Private Limited (“Elever,” “we,” “us” or “our“).
Scope of this Policy
This policy includes a description of your data protection rights as laid down under the law for the time being inforce.
Personal Information You Provide
You can access Elever website and information provided therein without divulging any personal information. Our Sites do not collect personal information about individuals except when such individuals specifically provide such information on a voluntary basis (for example, registering to avail our services, using and downloading Elever App; for conducting KYC check and as part of the Risk Questionnaire, accessing your 'Elever Money Score', consent based financial tracking, or providing Execution Consent for your Brokerage Account, requesting additional information by contacting us; signing up for newsletter; requesting help; or accessing, adding to, or changing the information on your account information/ registration/ signup window of the Elever App). When you register or sign up or Login to avail our services on our App, we may collect information regarding you. This personal information may be collected on our Sites, or via electronic mail or via telephone.
If you are using the Elever website as a first time visitor - The information we may collect includes certain data about your interaction with our website, such as pages visited and average time spent on the website, your internet protocol address, the unique identifier of your device and device information such as operating system, operating system version, browser plugins, crashes, system activity, hardware settings, date and time of your request and referral URL, and cookies that may uniquely identify your browser and mobile application. We use this data to analyze how you use our website and improve the information provided through the website. We may also supplement the information we collect with information we receive from third parties. For example, we may use marketing segments developed by us or other companies to customize certain services to your local area and provide relevant offers tailored to you.
In order to avail the services offered by or on the Elever App, users are required to register for an account on our Elever App and have to provide information and data (“Personal Information”) classified as ‘Sensitive Personal Information’ under Regulation 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”). Personal Information provided in acceptance of this Policy shall amount to written consent under Regulation 5 of the SPDI Rules.
As such the Elever App will have access to your name, Mobile number, Date of birth, PAN Number and email address only. This initial registration would involve providing a valid email, Mobile number, Date of birth, Permanent Account Number (“PAN”) and Name to generate the User name and password (collectively, “Login Credentials”) after due OTP verification. You may be asked to give us additional information in order to use certain features of the Elever App.
Further, we collect personal information when you are using our Financial Planning tools or registering with us for setting up of an Investment Account. This may include, inter alia, conducting KYC check and as part of the Risk Questionnaire, accessing the ‘Elever Money Score’, conducting KRA check, consent based financial tracking, or providing Execution Consent for your Brokerage Account. This information is primarily collected for regulatory compliance with applicable laws in order to enable/ create and/or activate your account with Brokerage Houses, to enable you to conduct online transactions. This information including KYC, Risk Questionnaire and financial information collected to generate the ‘Elever Money Score’ and to conduct consent based financial tracking shall be stored with us and shared with select third parties such as our group companies, KYC Registration Agencies (KRA), KYC solution providers, RBI approved Account Aggregators, Geo-Location based Intelligence providers, Brokerage Houses, Payment Gateway providers in order to enable us to complete your registration as a client with us and to process any transaction requests that you authorize, maintain a record of your transactions and holdings, generate and send reminders, alerts, notifications to you for transactions, recommended goals, upcoming funds transfers etc.
We may collect personal information about your transactions, and how you interact with third parties such as your brokerage house when you conduct trading transactions such as the purchase and/or redemption of securities, units in a mutual fund scheme. This information helps us to provide our services to you. We encourage you to read the Terms and Conditions to understand further about how your information is collected and used.
The personally identifiable information, such as your name, address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you choose to participate in various activities related to the Sites. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Sites.
Use of Your Information
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you to:
We generally do not disclose your personal information to other companies that provide services for us, where/ when such information is shared to it is disclosed on a need-to-know basis and based on specific consent. We may use third party service providers to enable us in providing some services to you such as opening and operating Brokerage account, conducting KRA check, conducting KYC check and onboarding, sending e-mail messages, SMS, WhatsApp and in-app notifications, analysis of non personally identifiable information for product/ service personalization, to you, customer support (online & offline) collecting a fee for our services, and providing product & technical support regarding an issue with any feature or functionality on the Sites.
When you provide us with your personal information either while setting up an account with us or later, it is kept maintained by the division that is responsible for your account management. You can view and/or update/edit this information by logging on to your account through our Elever app.
Personal information collected will not be used for any purposes other than as mentioned herein. You may withdraw your consent for the use of the personal information at any time by deactivating your account. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. In the event you choose to withdraw your consent for collecting and processing your personal data, we will be unable to provide you with our products and services.
Disclosure of Your Information
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
i. By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
ii. Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email/SMS/WhatsApp delivery, hosting services, customer service, and marketing assistance. Such third parties are required to maintain the confidentiality of the information we provide to them under contract and under law.
iii. Marketing Communications
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
v. Business Partners
We may share your information with our business partners to offer you certain products, services or promotions.
All employees of Elever have been selected in accordance with our strict security policies and practices and are bound by confidentiality obligations. Elever employees are subject to stern disciplinary action, including termination, civil liability, and criminal prosecution, if they fail to meet any of these obligations, as stated.
vii. No sale, distribution, trade, lease or rent of Personal information of users
Under no circumstances, Elever will sell, distribute, trade, lease or rent the Personal Information of its Users to anyone, for any reason(s).
We will not share or sell non-aggregated information contained within cookies to any third party.
You also have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If, however, you choose to decline cookies, you may not be able to fully experience the interactive features of our Sites or have some of our services on the Sites function properly, or at all.
Our Commitment to Data Security
Elever follows industry best practices, using open and known principles when transferring and storing your data. We believe the biggest threat to the security and privacy of your data is if someone – probably someone you know – gains access to any of your devices. Remember to keep your password safe and secret to prevent unauthorized access to your account. If you think that the security of your account has been compromised, change your password and contact us at firstname.lastname@example.org immediately for further assistance.
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect.
It may be noted that we may retain the data as may be provided to us till such time as may be provided under the law and as required to efficiently provide service to our users.
Exercise Your Rights
We respect your right to be informed, access, correct, request deletion or request restriction, portability, objection, and rights in relation to automated decision making and profiling, in our usage of your personal information as required by applicable law. We also take steps to ensure that the personal information we collect is accurate and up to date and deleted when data is no longer required. Your rights are subject to defined conditions and feasibility to exercise such rights and subject to geo locations applicability.
Our Legal Obligation to You
We are bound by the (Indian) Information Technology Act, 2000, and comply with all its provisions. Under Section 43A of the (Indian) Information Technology Act, 2000, Elever and all its Service Providers are obliged to maintain reasonable security procedures to safeguard your data. Under Regulation 5 of the Information Technology (Reasonable Security and Procedures and Sensitive Personal Data or Information) Rules, 2011, we are obliged to provide every registered user of Elever with a readable copy of the personal information you have provided us.