Privacy Policy

Last Updated: 21 November 2024

This Privacy Policy is published pursuant to Rule 4(1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and governs the collection, processing, and handling of personal and sensitive data.

1. General

BFD Innovations Private Limited (CIN: U70200DL2024PTC434732) ("the Company"), incorporated under the Companies Act, 2013, operates a technology platform, BharatFD ("Platform"), having its registered office at (Basement) plot no.11 DDA Site, New Rajinder Nagar, New Delhi – 110060, through its website and mobile application. The Platform facilitates investments in financial products, including fixed deposits, and may, from time to time, offer additional investment options ("Offerings on the Platform").

For the purpose of this Privacy Policy:

"You", "Your", or "User" refers to any individual who has signed up on the Platform and intends to use the Platform or avail of its Offerings.
"We", "Us", or "the Company" refers to BFD Innovations Private Limited, its subsidiaries, affiliates, or associates.

This Privacy Policy explains who processes Your data, how and why it is processed, and Your rights regarding control over Your data when using the Platform.

2. Acceptance

By accessing the Platform or availing the Offerings, You confirm that You have read, understood, and accepted the terms of this Privacy Policy. Your use of the Platform constitutes Your explicit consent to the collection, processing, storage, and disclosure of Your personal and non-personal information by the Company, its affiliates, and its partners, including banks and non-banking financial companies ("Partner Banks and NBFCs"), as required to provide the Offerings.

If You do not agree to this Privacy Policy, the Terms and Conditions of Use ("Terms"), or the Disclaimer Document, You must not access or use the Platform.

We reserve the right to amend this Privacy Policy periodically. It is Your responsibility to review the Privacy Policy for updates. Continued use of the Platform after amendments indicates Your acceptance of the revised terms.

3. Use on Behalf of Others

If You access or use the Offerings on behalf of another person (e.g., a child) or an entity (e.g., an employer), You represent and warrant that:

You are authorized to accept this Privacy Policy on their behalf, and
You consent to the collection, processing, storage, and disclosure of their data as described in this Privacy Policy.

4. Types of Data We May Collect from You

4.1. Data Collection and Usage

We, along with our affiliates, associates, Partner Banks, and NBFCs, may collect, process, use, share, and store your data to:

Provide and improve the Offerings on the Platform.
Enhance user experience and generate insights.
Comply with regulatory and contractual obligations.

4.2. Categories of Data Collected

5. Consent and Acknowledgements

5.1. Consent for Data Use

By using the Platform, you expressly consent to the collection, processing, storage, and sharing of your data with affiliates, associates, Partner Banks, NBFCs, and third-party entities (e.g., KRAs, financial institutions, and business partners) for the purposes listed above.

5.2. Data Collection Channels

We may obtain data through the Platform, communication channels, surveys, forms, and third-party integrations, as authorized by you.

5.3. Communications and Records

We may record and store phone calls, emails, and other communications for service improvement and regulatory compliance.
Feedback provided by you may be published on the Platform with your consent.

5.4. Retention

Your data will be securely stored for a reasonable period following the last use of the Platform or as required by applicable laws.

5.5. Acknowledgements

You confirm you are at least 18 years old and voluntarily provide your Personal Information.
You acknowledge that all collected data and communication records are confidential and will only be disclosed as required by law.

6. Purpose and Use of Your Data

We recognize the importance of protecting your Personal and Non-Personal Information and ensure its use strictly for lawful and intended purposes. By using the Platform, you consent to the collection, processing, sharing, and storage of your data in accordance with applicable laws for the following purposes:

6.1. Facilitation of Offerings

Establish and manage your investment account and process investment/redemption instructions.
Maintain records of transactions and holdings, and send reminders, alerts, and notifications.
Enable fund transfers between your bank account and Partner Banks/NBFCs.

6.2. Identity Verification and KYC

Verify your identity to allow access to Offerings.
Register, update, or check your KYC details with centralized KYC databases (KRA databases).

6.3. Customer Support and Communication

Resolve queries, provide support, and inform you of transaction progress or issues.
Notify you of offers, promotions, and marketing campaigns related to the Platform.

6.4. Data Analysis and Enhancement

Track and analyze usage patterns to enhance your experience.
Conduct research, analytics, and statistical studies to improve products, services, and features.

6.5. Business Operations and Compliance

Manage infrastructure, business operations, and internal policies.
Conduct credit checks, screenings, or due diligence as required by law.
Fulfill regulatory, legal, and reporting obligations, including financial and audit compliance.

6.6. Fraud Prevention and Security

Detect and prevent illegal activities, fraud, identity theft, cybersecurity incidents, and misuse of the Platform.
Share KYC and related details with affiliates to prevent abuse of services and Offerings.

6.7. Data Sharing and Third-Party Involvement

Share data with representatives, service providers, and business partners for lawful purposes.
Transfer data across borders for processing, subject to applicable laws and agreements ensuring data protection.
Provide anonymized or aggregated data to understand customer trends and improve business relationships.

6.8. Legal Disclosures

Share data with courts, government authorities, or law enforcement for identity verification, prevention of fraud, or compliance with legal obligations.

6.9. Cookie-Based Tracking

Use cookies to analyze trends, improve functionality, and optimize user experience.

6.10. Authorized Disclosures

Share KYC details with affiliates, associate entities, or subsidiaries for verification and transfer of units, subject to your consent.
Disclose Personal Information to auditors, legal advisors, and professional consultants under governed agreements.

6..11. Regulatory and Operational Transfers

Disclose data to comply with laws, directives, and orders from regulatory or governmental authorities.
Facilitate cross-border data transfers to affiliates, agents, service providers, and Partner Banks/NBFCs for legitimate purposes.
By using the Platform, you confirm your understanding and acceptance of these terms.

7. Consent to Data Sharing and Use

By using the Platform, you expressly understand, acknowledge, and consent to the following:

7.1. Sharing of Information with Affiliates and Partners

We may share or receive your Personal Information and Non-Personal Information with or from our affiliate entities, business partners, and associates to:

Provide and improve the Offerings on the Platform.
Enhance user experience and build affluence scores or user insights.
Outsource relationship management activities.
Analyze data for new services, features, and compliance with regulatory or contractual obligations.

7.2. Data Sharing in Corporate Transactions

In the event of a merger, acquisition, or restructuring involving the Company, your Personal and Non-Personal Information may be transferred to the new or combined entity, subject to applicable laws. Such entities will adhere to this Privacy Policy regarding your information.

7.3. Collection, Processing, and Sharing of Sensitive Information

We may collect, process, use, and store certain Personal Information, including but not limited to your PAN, date of birth, and residential status, to provide the Offerings on the Platform.
You expressly consent to the sharing of certain sensitive information provided by you, including financial details (e.g., debit card or payment information) and data collated from KRAs, with:
1. The Company and its Affiliates.
2. Partner Banks and NBFCs.
3. Affiliate entities and subsidiaries (current or future) to facilitate the delivery of Offerings.

This consent remains subject to compliance with applicable laws, ensuring that your information is processed securely and for lawful purposes only.

8. Links to Third-Party Websites

The Platform may provide links to third-party advertisements, websites, applications, products, or services (“Other Websites”) operated by entities outside our control and not affiliated with us unless expressly stated.
We are not responsible for any transmissions, content, or data shared with such Other Websites. Their privacy policies and terms of use will govern any information you provide or interactions you engage in. We do not endorse or guarantee the accuracy, integrity, or quality of content available on Other Websites. You are advised to review their privacy policies before use.

9. Data Retention

We may retain your Personal and Non-Personal Information for as long as necessary to fulfill the purposes for which it was collected, comply with legal, contractual, statutory, or regulatory obligations, or for internal reporting and compliance requirements.
Retention may extend beyond the termination of your use of the Platform, including the cancellation, deactivation, or non-subscription of your designated investment account.

10. Your Rights

You have the following rights with respect to your Personal Information, in accordance with applicable laws and this Privacy Policy:

Access and Portability: Request access to the Personal Information we hold about you or obtain a copy in a machine-readable format, or have it transmitted to a third party.
Rectification: Request correction of inaccurate or incomplete Personal Information.
Withdrawal of Consent: Withdraw your consent for the collection, processing, or storage of your Personal Information. Note: Withdrawing consent may impact or suspend the Offerings on the Platform.
Deletion: Request deletion of your Personal Information. Note: Deleting certain mandatory information may lead to the suspension of the Offerings on the Platform.
Content Usage: When you submit, store, or share content through the Platform, you grant us consent to use it for purposes specified in this Privacy Policy, including marketing, provided it does not:
1. Harm, harass, or defame individuals or entities.
2. Contain obscene, pornographic, or invasive materials.
3. Infringe intellectual property or violate any law.
4. Spread harmful software or threaten public order or national security.
5. Deceive, mislead, impersonate, or incite offences.
Submission of Requests: To exercise your rights, contact us at [email protected].

11. Limitations on Rights

Your rights may be restricted in circumstances where we are legally or contractually required to process, retain, or disclose your information.
Such limitations may affect the availability of the Offerings on the Platform and result in discontinuation of services if mandatory data cannot be processed.

12. Security Precautions

We employ encryption software to protect the transmission of your Personal Information and store it on secure servers and data centres with restricted access. Our systems are safeguarded with advanced security measures to prevent unauthorized access.
We have implemented robust information security standards, programs, and policies in compliance with applicable laws. These include managerial, technical, operational, and physical measures to protect your Personal Information from unauthorized access, use, modification, disclosure, or destruction.
Despite our best efforts, we are not liable for the confidentiality, security, or misuse of your Personal Information by third parties outside the scope of our agreements. We are also not responsible for breaches caused by factors beyond our reasonable control, including but not limited to governmental actions, hacking, technical failures, or internet service disruptions.
You acknowledge that no data transmission over the Internet is entirely secure, and any information shared with or through the Platform is done at your own risk.

13. Disclaimer of Information

You are solely responsible for ensuring the accuracy, truthfulness, and completeness of the Personal Information provided to us, our Affiliates, Partner Banks, and NBFCs. You agree to indemnify and hold us and our Affiliates harmless from any claims arising due to inaccurate or wrongful information provided by you.

To correct, delete, or amend inaccuracies, you may update your information on the Platform or contact us at [email protected].

14. Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time without prior notice. Changes will be effective immediately upon being updated on the Platform unless stated otherwise. You are encouraged to periodically review the Privacy Policy to stay informed of updates.

By continuing to use the Platform or avail of its Offerings after changes are posted, you signify your acceptance of the revised Privacy Policy. If you disagree with the changes, you may cease using the Platform and notify us at [email protected], upon which your access to the Platform will be suspended after confirmation.