Privacy Policy
Privacy
Policy For the purpose of this Privacy Policy, the “Vivek Financial
Group”, includes (i) Vivek Financial Focus Limited (“Vivek
Financial”) a private limited company incorporated under the
Companies Act, 2013 (CIN U74899DL1995PLC064632) and (ii) Lightpillar
Technologies Private Limited, ("LIGHTPILLAR") a private limited
company incorporated under the Companies Act, 2013 (CIN
U70200HR2023PTC116271); and (iii) includes all present and future
Affiliates of Vivek Financial and LIGHTPILLAR respectively. The term
“Affiliate” means with respect to an entity, the holding company,
subsidiaries and associate companies and shall include any other
entity, individual, firm, or corporation, directly or indirectly,
through one or more intermediaries, controlling, controlled by, or
under common control with such entity.
Vivek Financial Focus Limited, LIGHTPILLAR Technologies Private Limited and/or its affiliates ( “Lightpillar powered by Vivek Financial”/ “Company”/ “We”/ “Our”/ “Us” ) may become privy to some Personal Information ( defined below ) provided by individuals ( “Users”/ “You”/”Your” ), including information which may or may not be of confidential nature. We value Your privacy and recognises the importance of maintaining the privacy of Your Personal Information and appreciate Your trust in Us
For all intents and purposes of this Privacy Policy ( “Policy” ), Personal Information shall mean any information provided by You and/or available with the Company, which helps the Company identify You. However, no such information which is already available in public domain, or which can be furnished under Right to Information Act, 2005 or any law in force in India shall be considered as Personal Information under this Policy (“Personal Information”).
This Policy will help You understand the types of information we collect from You through Promotional Material (defined below) and/or the website, https://www.lightpillar.in (hereinafter referred as “Platform” ), which are owned, operated and maintained by Vivek Financial; the purpose for which the information is collected; how the information is used; the intended recipients of such information; and how the information is protected. If you would like more details, please contact us at [email protected]
By accessing / browsing the Platform; or providing information on the Platform or through any of the Promotional Material; or signing up for the Services ( as defined under the Terms of Use ) offered by LIGHTPILLAR powered by Vivek Financial; or providing Us with your personal information for any other purpose, you agree to the terms of this Policy and give consent to the Company to collect such information including personal information provided by You as per the Policy. This Policy is incorporated into and subject to the Terms of Use (“Terms”) of the Platform and shall be read harmoniously and in conjunction with the Terms. This Policy applies to all the information including Personal Information collected by Us.
1. Collection of Information
I.
Information You voluntarily submit
submit We collect Personal
Information from you when you voluntarily provide such information,
such as when you contact us with inquiries, register for access to
the Platform or purchase products or Services from the Platform.
a.
Using “LIGHTPILLAR powered by Vivek Financial” Platform as a Visitor
Every time you visit / access / use Our Platform, We collect
certain information about your interaction with Our Platform, such as
pages visited and average time spent on the Platform, your internet
protocol address, the unique identifier of your device and device
information such as operating system, operating system version,
browser plugins, cache, system activity, hardware settings, date and
time of Your request and referral URL, and cookies that may uniquely
identify Your browser, browser data, mobile application and mobile
information.
b. Interaction with “LIGHTPILLAR powered by Vivek Financial”’s
Promotional Material
We collect information which You may
provide while interacting with Our promotional material which
includes but not limited to promotional emails, newsletters and
advertising material (“Promotional Material”). This information
includes the number of clicks, time spent viewing the links from the
Promotional Materials, Your Personal Information, etc.
C.
Using “LIGHTPILLAR powered by Vivek Financial” as a Registered User
I. To complete your profile assessment, we may ask You
questions (questionnaire) related to your age, investing experience,
risk appetite for investments etc.
II. We shall collect Your Personal Information such as first name, last name, current contact and address details, email address, password, date of birth, signature, PAN, demat details, place of birth, city, country, complete address, pin code along with information regarding whether you are Politically Exposed Person (PEP) for the purpose of money laundering act and PMLA for The Foreign Account Tax Compliance Act (FATCA), your annual income/net worth, billing information, and ask to access Your LinkedIn profile link, Facebook link, Twitter link and Google account.
III. We may also ask for additional information in order to use certain features of the Services.
IV. We also collect technical data about Your interaction with the Services. The technical data includes but is not limited to Your internet protocol address, the unique identifier of Your device and device information such as operating system, operating system version, browser plugins, cache, system activity, hardware settings, date and time of Your request and referral URL, and cookies that may uniquely identify Your browser, browser data, mobile application and mobile device information.
V. We also collect Your IP address.
Our legal basis for processing this information is Your consent, and by voluntarily providing Us with Personal Information, You are consenting to Our use of it in accordance with this Policy. If you provide Personal Information to Us, You acknowledge and agree that such Personal Information may be transferred and stored from Your current location to the offices and servers of “Lightpillar powered by Vivek Financial” and the authorized third-parties referenced below.
“LIGHTPILLAR powered by Vivek Financial” shall not be liable for the authenticity/misrepresentation/fraud/negligence for the information provided by You. The Company shall also not be responsible for verifying any information provided by You. The sole liability for any misrepresentation/fraud/negligence/ any other criminal or civil liability emanating from the information provided by You shall be Your responsibility.
II. Information We Collect from Others:
We may receive
information about You from other sources such as when You use a
third-party software through the Platform, they may transfer
information to Us for fulfilment of their obligations under agreement
between such third-party and Us. For more information about our use
of third-party providers, please see further below.
III.
Information We Collect within the Vivek Financial Group:
We may receive information about You from an entity in the Vivek
Financial Group when You use the Services offered by such entity
through the Platform. Such entity within the Vivek Financial Group
may transfer the information to Us for providing relevant Services
and for fulfilment of their obligations under agreement, if any,
between the entities within the Vivek Financial Group.
IV.
Automatically-Collected Information:
We automatically collect certain information about You and the
device with which You access the Platform such as Your IP address,
operating system type, browser type, referring website, pages You
viewed, mobile application, mobile device information and the
dates/times when You accessed the Platform. We may also collect
information about actions You take when using the Platform, such as
links clicked.
V. Cookies:
We may log information using cookies, which are small data files
stored on your browser by “LIGHTPILLAR powered by Vivek Financial”.
We may use both session cookies, which expire when you close your
browser, and persistent cookies, which stay on Your browser until
deleted, to provide You with a more personalized experience on the
Platform.
2. Use of Your Information
We use all the collected data to:
a.
respond to Your queries about the Services;
b. send communications relevant to Your
use of the Services;
c. offer
You products or Services that We believe may be of interest to You;
d.tailor Your experience at the
Platform, providing You with content that We think You might be
interested in and to display content according to Your preferences;
e. to send You Promotional Material,
however, We will provide You the ability to opt-out of receiving such
emails from Us. If You opt out, the Company may still send You
non-promotional emails, such as emails about the Services, Your
account on the Platform and information on the use of the Platform;
f. ensure security on the Platform
and detect any errors, fraud and other criminal or otherwise
prohibited activity on the Platform;
g. aggregate the anonymised information
from registered Users to perform market research, project planning,
product development, troubleshoot problems, analyse User behaviour,
marketing purposes, and promotions;
h. identify and use Your IP address to
help diagnose problems with Our server, resolve such problems and
administer the Platform. Your IP address may also be used to help Us
identify You and to gather broad demographic information;
i.be compliant with Foreign Account Tax
Compliant Act (FATCA) and other applicable laws;
j. enforce Our Terms of Use; and
k. use Your information to verify
Your identity in the event You contact Us for assistance of Our
Services. We use cloud-based software tools to perform certain
business-related functions. Examples of such functions include,
maintaining databases and servers, processing text messages, phone
calls, chats and emails, and marketing and sales analytics.
3.
Connecting Your email/LinkedIn account
“LIGHTPILLAR powered by Vivek Financial” will seek Your consent to
connect/integrate Your email account(s)/LinkedIn account/Facebook
account/Twitter account/Google account with Your account on the
Platform by clicking on the authentication email sent by Us on Your
registered email address or by seeking permission on Your LinkedIn
account/Facebook account/Twitter account/Google account. We request
You to review the information prior to giving Your consent for
integration of the email addresses/LinkedIn account/Facebook
account/Twitter account/Google account with the account on the
Platform.
Once connected, the Platform will securely access and curate specific financial/investment/ other products and Services for You based on Your Financial transactions, investments and past financial behaviour. You may at any time opt to de-link Your email addresses and LinkedIn account connected with the account on the Platform, by managing these connections with the options provided on the Platform. Such de-linking can also be achieved by reviewing permissions on the email account or linked-in account.
4.
Links to Other Third – Party platforms and collection of information
“LIGHTPILLAR powered by Vivek Financial” may link You to other
third-party platform that may collect Your Personal Information such
as Your IP address, browser specification, or operating system.
“LIGHTPILLAR powered by Vivek Financial” does not take responsibility for the security of such information or their privacy practices or content of those third-party platforms. Additionally, You may also encounter “cookies” or other similar devices on certain pages of the third-party platform and We clarify that the “LIGHTPILLAR powered by Vivek Financial” Platform does not control the use of cookies by these third-party platforms. These third-party service providers may have their own privacy policies governing the storage and retention of Your information that You may be subject to. This Policy does not govern any information provided to, stored on, or used by these third-party providers. You are advised to review the privacy policy of these third-party Platform.
5.
How We Use Technical Data
“Lightpillar powered by Vivek Financial” uses third-party web
analytics service providers such as Google Analytics, Clevertap,
Hotjar and Clearbit. These web analytics services aggregate Personal
Information, geographical data and other cookies based data. We use
this information to identify the most popular areas of the Services
and how to best present and customise them. We may use the unique
identifier of Your device for security purposes to track suspicious
activity. For instance, if We detect that Your Lightpillar account is
being accessed from multiple devices, We may contact You to ensure
that You have authorised such access. You consent to process the
information provided by You including Personal Information through
third party web analytics service providers in accordance with this
Policy.
6.
Access and Update Your Personal Information
If You want to review your Personal Information or believe that the
Personal Information provided by You on the Platform or through
Promotional Material is inaccurate or not up to date or have any
questions about the accuracy or safety of Your Personal Information,
please do contact Us at [email protected].
7.
Disclosure of Information
Except as provided in this Policy, “LIGHTPILLAR powered by Vivek
Financial” will not transfer, sell or rent Personal Information
collected to anyone, for any reason, at any time. “LIGHTPILLAR
powered by Vivek Financial” shall also ensure reasonable care and
prevention of any unauthorised disclosure of Your sensitive Personal
Information. “LIGHTPILLAR powered by Vivek Financial” will share Your
information with judicial, administrative and regulatory entities to
comply with any legal and regulatory requirements under applicable
laws.
8.
Payment Information
You may provide payment information when You use the Platform to
avail Our Services such as debit card numbers, billing information
using third-party intermediary PCI-DSS compliant service providers.
The payment information is provided directly by You, via the
Platform, into the PCI/DSS-compliant payment processing service to
which “LIGHTPILLAR powered by Vivek Financial” subscribes, and
“Lightpillar powered by Vivek Financial” does not, itself, process or
store the payment information. Further, these intermediaries are not
permitted to store, retain, or use Your billing information for any
purpose except for payment processing on Our behalf.
9.
Retention of Personal Information
“LIGHTPILLAR powered by
Vivek Financial” will keep Your Personal Information as long it is
required for the purpose for which it has been collected including to
make available the Platform and provide Our Services or for other
legitimate purposes, such as complying with legal obligations,
enforcing and preventing violations of our Terms of Use, or
protecting or defending our rights, property and users. The storage
periods are determined on a case-by-case basis that depends on
factors like the nature of the information, why it is collected and
processed, relevant legal or operational retention needs, and legal
obligations. “LIGHTPILLARpowered by Vivek Financial” will make sure
to delete any Personal Information collected and stored by it once
the purpose has been fulfilled or the Personal Information is no
longer needed by “LIGHTPILLAR powered by Vivek Financial”.
10. Personal Information of Minors
“LIGHTPILLAR powered by
Vivek Financial” may collect and/or store Personal Information of
persons under the age of 18 years ( "Minors" ) that their parent or
guardian under applicable laws, provide on the Platform to avail the
Services. While providing Personal Information of the any Minor, the
parent or guardian under applicable law, gives consent to
“Lightpillar powered by Vivek Financial”, to store / use such
Personal Information of Minors as per the Policy.
11.
Customer Care
If You have any complaints or queries
regarding Your Personal Information or the Policy, please contact:
Name - Saurabh Malhotra
Email - [email protected]
12.
Deletion
In the event that Your Personal Information is
deleted from Our servers due to application of law, withdrawal of
Your consent or due to any other reason, You agree that You will not
access any or all Our Platforms or Services.
13.
Security Practices and Procedures
Our Platform has stringent
security measures in place to protect the loss, misuse, and
alteration of the information under Our control. Whenever You as a
Registered User change or access Your account information, We offer
the use of a secure server. Once your information is in Our
possession We adhere to strict security guidelines, protecting it
against unauthorized access. We are in compliance with privacy laws
of India and are not bound by privacy laws of any jurisdiction other
than India.
“LIGHTPILLAR powered by Vivek Financial” follows industry best practices, using open and known principles when transferring and storing Your data. All the User data is stored securely on cloud. However, “LIGHTPILLAR powered by Vivek Financial” cannot guarantee absolute security as no security measure can provide 100 % security of the information transmitted on internet or electronically stored on servers.
We also train and require Our employees to safeguard Your information. We also use physical, electronic and procedural safeguards and provide access to Personal Information only to employees, agents and/ or Affiliates on a need to know basis.
We assume no liability for any disclosure of information due to errors in transmission, unauthorised third-party access to Our Platform and data bases or other acts of third-parties, or acts or omissions beyond Our reasonable control and You shall not be entitled to hold “LIGHTPILLAR powered by Vivek Financial” responsible for any breach of security. In the event “LIGHTPILLAR powered by Vivek Financial” becomes aware of any security breach, it will notify You as soon as possible and take appropriate action to the best of its ability to remedy such a breach.
If You think that the security of Your “LIGHTPILLAR powered by Vivek Financial” account has been compromised, You shall change Your password and contact Us immediately for further assistance.
14.
Use of Google API server data
“LIGHTPILLAR powered by Vivek
Financial” use of information received from Google APIs will adhere
to Google API Services User Data Policy, including the Limited Use
requirements.
15.
How Your Information is Transmitted and Stored
Your
information including Personal Information is transmitted between
Your device and Our servers using HTTPS protocol for encryption.
HTTPS is the technology used to create secure connections for Your
web browser and is indicated by a padlock icon in Your browser. In
addition to HTTPS, We make sure that Your Personal Information is
always encrypted or hashed before We store it. We use industry
standard encryption and hashing algorithms.
16.
Consent Withdrawal
If You wish to withdraw Your consent given
under this Policy for collection and use of any Personal Information,
You can withdraw Your consent by sending Us an email at
[email protected].
17.
Grievance Officer
In accordance with Information Technology
Act 2000 and rules made there under, the name and contact details of
the Grievance Officer are provided below:
Mr. Saurabh Malhotra
[email protected]
18.
Legal Obligation and Jurisdiction
“LIGHTPILLAR powered by
Vivek Financial” is bound by the (Indian) Information Technology Act,
2000 and rules made thereunder, and it shall comply with all its
provisions. Under Section 43A of the (Indian) Information Technology
Act, 2000, “Lightpillar powered by Vivek Financial” and all its
vendors are obliged to maintain reasonable security procedures to
safeguard Your data.
Any disputes arising under this Policy shall be governed by the laws of India.
19.
Updates to this Policy
This Policy was last updated on
February 9, 2024 ("Last Update Date"). From time to time We may
change Our Policy. We will notify You of any material changes to this
Policy as required by law. We will also post an updated copy of the
Policy on Our Platform. Please check Our Platform periodically for
updates on the Policy. Changes to this Policy will be effective as of
the stated Last Update Date mentioned in the Policy. By continuing
using the Platform i.e. by providing information on the Platform /
browse the Platform / access the Platform / use the Services provided
by the Company on the Platform, after any change in this Policy, You
agree with the modified and updated Policy and provide consent to the
collection of information including Personal Information disclosed by
You on the Platform according to terms of such modified Policy.