Why
Sqrrl Fintech Private Limited (“Sqrrl” / “SQRRL”) is in the business of distribution of financial products through its online technology platform. Sqrrl is a AMFI registered Mutual Fund Distributor with ARN 112848 and provides mutual funds on mobile application and website
We at Sqrrl have set this privacy policy to ensure that we will protect any information that you share when you use this website. We herewith disclose our privacy practices and encourage you to read our privacy statements to understand our policy.
Sqrrl is committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. We ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy statement.
Sqrrl reserves the right to modify sections of this Privacy Policy at any time without giving any prior notice any such change of policy will be may be effective from the date announced by us on the Website and not from the date of posting on the site. Please check this policy from time to time for any changes.
Users’ Personal Information
1. Collection of Users’ Personal Information
A. We may collect the following information
- Name
- Contact Details (Permanent Address, Correspondence Address, Email ID, Mobile No etc)
- Date of Birth, Place of Birth and Nationality.
- Permanent Account Number (PAN)
- Demographic information such as gender and income
- Additional KYC and FATCA details
- Picture
- Self-attested documents
B. Other sources
Sqrrl may collect public and non-public information/details (personal, financial, etc.,) about you from any of the following sources for its lawful business/operational purposes
- You or your authorized agents through application form (information/details like name, address, birth date, income, etc.)
- Financial information such as bank account details (e.g. bank account number, cheque details, etc.)
- Risk profile, investment selection, beneficiary information etc.,
- Any other documentation supporting the above information/details.
C. SMS transaction data (for Sqrrl Away round-ups in Android)
We request permission to view your SMS messages for the purpose of setting up a core feature “Sqrrl Away”, where we round-up the transaction amounts to nearest 100 and invest the spare change in a liquid scheme of mutual funds. Post collecting the SMSes, Sqrrl will only store purchase transactions SMSes sent by 6-digit alphanumeric senders to apply the round-up logic on transaction amounts for investment. We will only store messages that are relevant to this purpose and will not store irrelevant or personal messages in any form or manner. The permission is voluntary and can be revoked at any time. However, denying access may lead to the “Sqrrl Away” feature not working. This data is never shared outside the Sqrrl domains/subdomains (https://api.sqrrl.in); and is used solely for the purpose of calculating round-up amounts for the “Sqrrl Away” feature
D. Phone Data
Sqrrl may collect information like device location, device information (including storage, installed apps, Wifi, mobile network), transactional and promotional sms, communication information including contacts, with your consent, for the purpose of evaluating loan applications and offering loans.
We also collect information from or about the computers, mobile phones, or other devices where you install or access our services, depending on the permissions you’ve granted. We may associate the information we collect from your different devices, which helps us provide consistent services across your devices. Here are some examples of the device information we collect
- Attributes such as the operating system, hardware version, device identifiers.
- Connection information such as the name of your mobile ISP, browser type, language and time zone, mobile phone number and IP address.
2. What we do with the information we gather
We require this information for the following reasons:
- To conduct Know-Your-Customer registration as required by AMFI and/or other regulatory bodies
- To perform compliance checks and keep/maintain internal records
- To use the information to improve our products and services
- To periodically send emails to your registered email address about your investments, or other information which we think you may find interesting
3. Data Sharing
Sqrrl may share any clients’/investors’ information (personal/financial, etc.,) with the following parties, in connection with and as may be necessary for the conduct of Sqrrl’s business/operations
- With the Registrar & Transfer Agent(s) (RTA) of various Mutual Funds/other Issuers, Banks and/or authorised external third parties/intermediaries or any other service provider who are involved in transaction processing, dispatches, printing/marketing etc. of clients/investors investment in any products, unless any investor/unitholder have specifically written to Sqrrl to refrain from sharing such information with such parties
OR
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Any regulatory/administrative/legislative authority and/or with the Sqrrl for compliance with any legal, statutory or regulatory requirements and/or to verify the identity of clients/investors for complying with anti-money laundering/KYC requirements and/or under any applicable laws for the time being in force and/or for the purpose of data storage Sqrrl shares such aforesaid information to the aforesaid service providers (e.g. RTA, Banks, etc.) under strict confidentiality and only on a ‘need to know basis’ and for the purposes of lawful functioning of Sqrrl’s business/operations.
Sqrrl sends the account statements or financial information pertaining to the clients/investors to be sent over the internet and only through a secure mode. Sqrrl also ensures that the parties to whom such aforesaid information/data is shared have confidentiality provisions and high levels of security practices, controls and procedures to ensure its protection.
Notwithstanding anything contained, Sqrrl shall not be responsible/liable, either directly or indirectly, for the authenticit/accuracy of the personal/financial information or any other data/information submitted by you and/or for its misuse, not attributable to the acts of Sqrrl, at any time and in any manner whatsoever.
Security
- We treat your personal information or your use of the Service as private and confidential and do not check, edit, or reveal it to any third parties except where it is believed to be in good faith, such action is necessary to comply with the applicable legal and regulatory processes, or to protect and defend the rights of other users or to enforce the terms of service which are binding on all the users.
- Except where specifically agreed or necessary for operational or regulatory reasons, we will not send you any unsolicited information. Howzever, to help you to take full advantage of our services, messages relating to our products/services and/or changes, additions and improvements to the products/services offered may be sent to you.
- The Website is not intended for use by children and minors. Parents are requested to ensure that personal information is not provided by minors on the Sqrrl website. However, this does not intend to prohibit information on minors and children being provided by the parents with respect to any product or service offered by us or any other third party permitted to offer any product or service on its site, which are beneficial to or are designed for the benefit of children and minors.
- We use the help of Internet Protocol (“IP”) addresses to diagnose any problems with its server and to administer the web site including by blocking certain addresses that it feels are inappropriately using its website. IP addresses are used to gather broad demographics information, such as browser types, visitor’s country, visiting frequency, operating systems, etc.
- Firewalls and DMZ Although we provide appropriate firewalls and protections, our systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible and Company takes no liabilities or responsibilities for it. The best security available and provided by infrastructure will be applied to secure data.
How we use cookies
- Users are also made aware that certain information and data may be automatically collected through the standard operation of our internet servers or through the use of “cookies.” “Cookies” is a term generally used for small text files a web site can use to recognise repeat users, facilitate the user’s ongoing access to and use of the site, allow a site to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising etc. Cookies themselves do not personally identify you, but they do identify your computer. Generally, cookies work by assigning a unique number to the user computer that has no meaning outside the assigning site.
- Users are also being made aware that we cannot control the use of cookies or the resulting information by advertisers or third parties hosting data for us. If a user does not want information collected through the use of cookies, there is a simple procedure in most browsers that allows the user to deny or accept the cookie feature; however, users should note that cookies may be necessary to provide the user with certain features (e.g., customised delivery of information) available from us. If you choose to be a registered user of the website, you must accept a cookie from the website.
Link to other websites
- Our website may contain links to other websites of interest, without any accuracy, completeness, or usefulness of any content, warranty, merchantability, endorsement, suitability, any assurance of quality, authenticity, and appropriateness to view such websites and responsibility, liability, obligations on part of this website.
- This Privacy Policy does not apply when you access to such sites or links. However, once you have used these links to leave our site, you should note that we do not have any control over such third-party websites. Such third party websites may also transmit cookies to you.
- Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. You should exercise caution and look at the privacy statement applicable to the website in question.
Notes
- If you believe that any of your information with us is incorrect or incomplete, please email us as soon as possible at happy2help@sqrrl.in . We will promptly correct any information found to be incorrect.
- If at any time you believe that the website or its users/members have not adhered to these principles, please notify by e-mail happy2help@sqrrl.in and we will use all commercially reasonable efforts to promptly determine and correct the problem.
- You will be free to unsubscribe from our mailing list at any time if you do not wish to receive such emails from us. From time-to-time, we may also use your information to contact you via phone or email for market research purposes.
- We will not sell, distribute or lease your personal information to third parties unless we are required to share such information under the terms and conditions of the products and services you avail, or we are required to do so by law.
- This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in favour of any user or viewer of the website or on behalf of any other party.
- However, users and viewers are informed that by using the web site they are deemed to have consented to the collection and use of information by us as stated above.
The web site is maintained by Sqrrl Fintech Private Limited, having its registered office at 33, Commercial Shopping Complex, Anand Niketan, New Delhi – 110021, India.