Finacular Privacy Policy

We are committed to keeping your data secure, your private information private, and being transparent about our practices.

 

Finacular operates mobile applications and websites https://www.finacular.in under brand names Finacular.

 

Finacular enables you to track, save and earn extra potential returns by automatically bringing your entire financial life across savings, investments, loans, credit cards & taxes, all in one application.

 

Finacular is committed to operating its website and mobile applications with the highest ethical standards and appropriate internal controls. We take your privacy extremely seriously. Your privacy is important to us and maintaining your trust is paramount. This Privacy Policy explains how Finacular collects, uses & protects your information when you access Finacular website(s) & mobile apps (collectively referred to as “Services” or “Application”). We encourage you to read this Privacy Policy. By using Finacular Services you agree to the terms of the Privacy Policy. If you are not comfortable with any of the terms or policies described in this Privacy Policy, you may choose to discontinue usage of Finacular Services. You can also email us at hello@Finacular.in to update or delete your personal information that Finacular has collected.

 

 

What Information does Finacular collect?

We receive and store only that information you knowingly provide to us or with your explicit consent. You can always delete this information by writing to us at privacy@Finacular.in

 

Below is the list of information we collect.

 

New Account : When you create a new account to use the Services we may request for the following information :

Mobile number, First name, last name, PAN number(Tax Number), email, date of birth

Income slab, profession, address details, father’s name, mother’s name, tax residency, birth country, nationality, nominee details, gender, marital status

Bank account number, your name on bank passbook and IFSC code of the bank.

Permanent Account Number (PAN No) & Bank account details that you will use for the purpose of investments and transactions.

KYC details: To comply with regulatory requirements, based on your explicit consent we fetch your KYC (Know Your Customer) details from regulated Central KYC Registry.

Credit score & Liabilities information : You provide an explicit consent to Finacular to collect this information from third party service provider  that are expressly authorised by you to distribute such information (for example, Experian or CRIF High Mark which is a credit information company registered under the Credit Information Companies (Regulation) Act, 2005)

Access to your email is sought to provide a holistic view of your card payment due dates, statements from the applicable services etc. The Finacular website/app will securely store account details for each of your credit card accounts, including your sign-in user name and authorisation tokens for tracked accounts. This information will be used to enable Finacular website/app to automatically access your applicable credit card statements to analyze, extract, and store information securely from such accounts for use in the Finacular website/app.

 

Finacular will automatically access the contents of emails on an ongoing basis for the purpose of managing complete credit card lifecycle including credit card statements, due date reminders, spend patterns and related rewards etc.

 

 Investments information : We provide the following options for you to update your investment information in a secure manner :

 

(i) Upload your investment statements in PDF or Excel versions.

 

These are investment statements that you get from depositories or brokers or Registrar & Transfer Agents such as Computer Age Management Services, Karvy Fintech Private Limited, National Securities Depositories Limited, Central Depositories Services Limited, etc.

 

You provide explicit consent to Finacular to fetch these statements from https://new.camsonline.com/Investors/Statements/Consolidated-Account-Statement and https://mfs.kfintech.com/investor/General/ConsolidatedAccountStatement.

 

 (ii) Enter the information manually

 

You provide investment details like scheme name, investment type, investment date and investment value by manually entering the data.

 

 (iii) Connect your Gmail account

 

You can choose to provide explicit consent to connect your Gmail account with Finacular account (using Google’s OAuth authentication method), so that the application / website can “read only” the attachment from a small white listed set of senders specifically comprising :

 

donotreply@camsonline.com

samfd@karvy.com

nsdl-cas@nsdl.co.in

eCAS@cdslstatement.com

NSE-direct@nse.co.in

samfd@kfintech.com

samfS@kfintech.com

CRA@NSDL.co.in

KCRA@kfintech.com

enq_H@camsonline.com

enq_P@camsonline.com

axismf@kfintech.com

enq_k@camsonline.com

nimf.txn@kfintech.com

enq_L@camsonline.com

nimf.pur.txn@kfintech.com

utimf@kfintech.com

If the sender email ids are changed then we will notify you and also update this Privacy Policy.

 

 The attachments from these senders have the details of your investments such as Folio numbers, Transaction Dates, Dividends, Subscription and Redemption Amounts, etc. Finacular organises this information in your account to provide deep analytics.

 

 The benefit of opting to connect your Gmail account is that your investment information gets updated automatically every month. Given the updated information, the application can hence give you deep and accurate analytics on your investments.

 

 You can choose to de-link your Gmail account with the application at any time and/ or you can delete your information by writing to hello@Finacular.in

 

 Alternatively, you can also de-link your email by visiting Google Mail’s permission settings located at: myaccount.google.com/permissions

 

 Please note we will never rent or sell your information or data to anyone. We never use or transfer the data collected on our application for serving ads, including retargeting, personalized, or interest-based advertising.

 

 This act of connecting your Gmail accounts with Finacular accounts comes under the “Restricted scopes” under Google API services user data policy. Please also refer to Privacy Policy with respect to the restricted scope as mentioned in the sections below.

 

(iv) Employees Provident Fund Passbook (“EPF passbook”) details:

 

You can choose to provide explicit consent to Finacular to collect this information from https://passbook.epfindia.gov.in/MemberPassBook/Login, by providing your 12-digit Universal Account Number, assigned to you as a member of EPFO, and the related password. Your EPFO password will be stored by Finacular at a local device in encrypted format and will be stored on our server in encrypted format. We use AWS Key Management Service Feature for storing your EPFO password. This will enable Finacular to consolidate and present your comprehensive EPF passbook data. This will also help you to get an accurate picture of your overall investment details on your Finacular dashboard.

 

(v) National Pension Scheme (“NPS-Tier I”) statement details:

 

You can choose to provide explicit consent to Finacular to collect this information from your NPS-Tier I statement assigned to you as a member of NPS-Tier I, and the related password to open the NPS Tier I statement. Your NPS-Tier I statement password will be stored by Finacular at a local device in encrypted format and will be stored on our server in encrypted format. We use AWS Key Management Service Feature for storing your NPS-Tier I statement password. This will enable Finacular to consolidate and present your comprehensive NPS-Tier I data as well as provide tax saving advisory which includes NPS. This will also help you to get an accurate picture of your overall investment details on your Finacular dashboard.

 

You can choose to de-track NPS-Tier I Investments anytime from the NPS-Tier I Investments section or by writing to hello@Finacular.in.

 

Your Expenses and Saving Account analytics via SMS (Short message service) on your Android phone (Applicable for only Android phones) :

 

You can choose to provide specific & explicit consent to allow Finacular’s Android App to access your text messages (SMS) inbox received on your Android mobile device. After obtaining such explicit consent from you, Finacular's Android App may automatically read your SMS text messages pertaining to yours expenses and/or saving account balance data information arising out of transactions made from cards, banks, wallets through text messages (SMS) received by you from providers of services and/or banks (including but not limited to retail outlets, financial institutions, and utility companies) on your Android mobile device. This will enable us to organise your expenses and saving account balances across your transactions and banks in one view and also provide analytics on the same to you. This will also help you to get an accurate picture of your overall wealth and networth on your Finacular dashboard.

 

No personal SMSes or OTPs are accessed by Finacular.

 

You can choose to opt-out of the expense and saving account balance analytics services at any time by writing to hello@Finacular.in

 

Alternatively, you can also opt-out of the expense and saving account balance analytics by visiting Finacular’s Android App permission settings.

 

Why does Finacular ask for this information?

Finacular is a Wealth management platform that provides online financial advisory services to you. We receive information you knowingly provide to Finacular or with your explicit consent. This information enables you to organise and aggregate your financial information in one place on Finacular Services. This also enables Finacular to provide you analytics on your investments, liabilities & expenses all in one place. The information also enables Finacular Application to help you assess your risk profile from time to time and create your investment plans and make decisions on investments & execute purchase and sale of investment products and also enables you to manage your taxation.

 

Cookies & Third Party Analytics Services

We use Local Storage Objects (LSOs) to store content information, preferences and to keep you signed-in. We identify user’s signed-in state with a token and a userid. The LSO token is expired when user logs out of our website or mobile application.

 

 We do not collect any information about your online activity when you sign-out and/or leave our services.

 

 We use third party analytics services in order to better understand user engagement with the Services. When a user browses or uses the Services, these third party analytics services may collect the user’s IP address, browser type, and approximate location (based on the IP address). They may also use web logs or web beacons and may set and access cookies on your computer or other device. In order to provide a superior user experience, we provide the third party analytics service providers with a user’s demographic information at Finacular along with user’s movements on Finacular website and mobile applications.

 

 These third party analytics services may deploy cookies on your browser. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked.

 

 We do not share and will never share any confidential data such as user’s investment details, contents of user’s gmail, bank details, transaction details, income or any other sensitive details with these third party analytics service providers.

 

Does Finacular Share Personal Information?

We neither rent nor sell your personal Information to anyone.  However, we may share your Personal Information with third parties as described in this section:

 

We only transfer the data to others if necessary to provide or improve user-facing features that are prominent in the requesting application's user interface. We may also transfer data as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to users. All other transfers or sales of the user data are prohibited

We don't use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising; and

We don't allow humans to read the data, unless :

(a) We first obtain your affirmative agreement for specific purposes;

(b) It is necessary for security purposes (such as investigating a bug or abuse);

(c) It is necessary to comply with applicable law; or

(d) Our use is limited to internal operations and the data (including derivations) have been aggregated and anonymized.

 

These prohibitions of user of data apply to all the information/ data  obtained from you with your explicit consent .Our employees, agents, contractors, and successors comply with this Policy.

 

Your personal information with respect to connecting your Gmail account with Finacular Application :  Compliance w.r.t. Google OAuth API Scopes (Restricted scopes)

 

We will never rent or sell your information or data to anyone. Finacular ensures that it is always in compliance with the restricted scope defined under Google OAuth API policies.

 

Finacular limits use of data to providing or improving your user experience. Connecting your Gmail account with Finacular is completely optional and based on your explicit consent for only specific use cases as has been described in this Privacy Policy. The benefit of this option is that you do not need to keep updating your investment information every month. Given the updated information, the application can hence give you deep and accurate analytics on your investments. You can choose to de-link your Gmail account with the application at any time and/ or you can delete your information by writing to hello@Finacular.in

Alternatively, you can remove access to Finacular from Google Mail’s permission settings located at: myaccount.google.com/permissions.


 

Your SMS information with respect to giving explicit permission to Finacular application with respect to your SMSes related to expenses & saving account balances (Personal & Sensitive information):

 

We will never rent or sell your information or data to anyone. Finacular ensures that it is always in compliance with the Google Play store policies and Google policies.

 

Finacular limits use of data to providing or improving your user experience. Giving consent to access your SMS text messages (on your Android phone) to Finacular Android App is completely optional and based on your explicit consent for only specific use cases of organising your expenses and saving account balances and as described in this Privacy Policy. The benefit of giving explicit consent for this option is that Finacular Android application is enabled to organise all your fragmented expenses across your transactions and saving accounts across your banks on the Finacular App dashboard. Finacular Android application is also enabled to give you analytics across your expenses and saving account balances. This also helps you to get an accurate picture of your overall NetWorth and overall financial picture in combination with your investments & liabilities. You can anytime choose to opt-out of this permission by visiting the Finacular App's permission settings or you opt out by writing to hello@finacular.in ; You can also ask to delete your information by writing to hello@finacular.in

We do not use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising and we do not allow and we prohibit access to any of the third party analytics providers.

 

We don't allow humans to read the data, unless :

(a) We first obtain your affirmative agreement for specific messages;

(b) It is necessary for security purposes (such as investigating a bug or abuse);

(c) It is necessary to comply with applicable law; or

(d) Our use is limited to internal operations and the data (including derivations) have been aggregated and anonymized.

These prohibitions of use of data apply to the raw data obtained from your SMS and data aggregated, anonymized, or derived from them. Our employees, agents, contractors, and successors comply with these policies.

 

Changes to Privacy Policy

Finacular reserves the right to change this policy from time to time. Any changes shall be effective immediately upon the posting of the revised Privacy Policy. While we will make reasonable efforts to keep you posted on any updates to this privacy policy, to make sure that you are aware of any changes, we recommend that you review this policy periodically. If you are not comfortable with any of the changes to Privacy Policy you may choose to discontinue usage of Finacular website or mobile applications. You can also email us at hello@finacular.in to update or delete your personal information that Finacular has collected.  

 

Privacy Questions and Access

If you have questions, concerns, or suggestions regarding our Privacy Policy, please contact us immediately at hello@finacular.in.

 

In certain cases, you may have the ability to view or edit your personal information online. In the event your information is not accessible online and you wish to change or delete your personal information or other information that you may have provided, please contact us immediately at hello@finacular.in

 

The Prevention of Money Laundering Act 2002 and SEBI (Investment Advisors) Regulations, 2013 require record retention for a period of up to 5 years post the deletion of your account. In the event of the pendency of any legal/ regulatory proceeding or receipt of any legal and/or regulatory direction to that effect, we may retain your information for a longer period.

 

Security and Responsible Disclosure

We at Finacular are committed about our client's data and privacy. We blend security at multiple steps within our products with state of the art technology to ensure our systems maintain strong security measures. The overall data and privacy security design allows us defend our systems ranging from low hanging issue up to sophisticated attacks. You can read more about it here.

 

If you are a security enthusiast or a researcher and you have found a possible security vulnerability on Finacular, we encourage you to report the issue to us responsibly.

 

You could submit a bug report to us at hello@Finacular.in with detailed steps required to reproduce the vulnerability.

 

We shall put best of our efforts to investigate and fix the legitimate issues in a reasonable time frame, meanwhile, requesting you not to publicly disclose it. Additionally, if you have suggestions on how we could improve our security systems to make it more robust and safe for all users, you can share those with us at hello@Finacular.in