Privacy Policy

This privacy policy document ("Privacy Policy") is published in accordance with the provisions of Rule 4 (1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information.

General

1. Stable-Alpha Technologies Private Limited is a company incorporated under the Companies Act, 2013 (CIN: [ U74999KA2022PTC167343]) (“the Company”) that provides a technological solution to facilitate investments in various financial products inter alia includes fixed deposits, debt mutual funds, government bonds and sovereign bonds ( "Offerings on the Platform"), through Stable Finserv Private Limited ( "Distribution Partner") and Stable Broking Private Limited ("Broking Partner"), collectively referred to as "Affiliates" on the website and mobile application of the Company "Stable Money" ("Platform"). From time to time, the Platform may allow users to invest in other investment products.
2. For the purpose of this Privacy Policy, wherever the context so requires, "You" or "Your" or "User" shall mean any natural person who has already signed up on the Platform and intends to access the Platform and/or avail the Offerings on the Platform. Further, wherever the context so requires, "We","Us" or "the Company" shall mean Stable Alpha Technologies Private Limited, a company registered under the Companies Act, 2013 (CIN: U74999KA2022PTC167343), having the registered office at Third floor, Block A, Stable Money, Bhive HSR Premium Campus, Krishna Reddy Industrial Area, Kudlu gate, Bommanahalli, Bangalore, Karnataka, India, 560068, or its subsidiaries, associates/affiliates.
3. This Privacy Policy provides specific information on who is processing Your data, how and why it is being processed and Your rights with regard to the control over Your data when availing of the Offerings on the Platform.
4. Please read the terms of this Privacy Policy carefully before accepting. By accepting the terms of the Privacy Policy, You agree that You have read, understood, acknowledged and accepted this Privacy Policy to access and use the Platform. By directly or indirectly using the Platform, and/or having availed the Offerings on the Platform, in the past, present or future, You explicitly consent to the collection/ sharing/ processing/ use/ storage/ disclosure of Your "Personal Information" and "Non-Personal Information" by Us and our sub-group/ affiliate companies/ banks and non-banking financial corporations partnered with the Company ( "Partner Banks and NBFCs") for providing the Offerings on the Platform to You in compliance with this Privacy Policy. We reserve the right to update the terms of the Privacy Policy from time to time. Please ensure that You read the terms of the Privacy Policy periodically to stay updated on the latest version of the Privacy Policy. If You do not accept the terms of the Privacy Policy, the terms and conditions of use (“Terms”) and the Disclaimer Document, You must not access or use the Platform.
5. If You use the Offerings on the Platform on behalf of someone else (such as your child) or an entity (such as your employer), You represent that You are authorised by such individual or entity to (I) Accept the Privacy Policy on such individual’s or entity’s behalf, and (II) consent on behalf of such individual or entity to our collection/ processing/ use/ storage and disclosure of such individual’s or entity’s information as described in this Privacy Policy.

Types of Data that we may collect from You

1. We, the Affiliates and our associate/ affiliate entities/ may collect/ receive/ share/ process/ use/ store Your information to the extent required to provide the Offerings on the Platform, enhance the user experience, build affluence scores/ user insights, analyse data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations. We may collect/ receive/ share/ process/ use/ store the following information about You as well as the device from which You avail the Offerings on the Platform.
2. “Personal Information” will inter alia include any information which is directly or indirectly available to Us to identify or verify individual identity. This may also include sensitive personal data which inter alia includes financial information such as bank account, debit card details, and biometric information.
3. “Non-Personal Information” may be collected by Us which cannot be used to identify an individual, while he/she uses the Platform. This information inter alia includes IP address, browser type, and name of the individual’s internet service provider.
4. Categories of data/ information which We, the Affiliates and our associate/ affiliate entities/ Partner Banks and NBFCs may collect/receive/ share/ process/ use/ store in order to serve You through the Platform:
   
   

   Categories of Data	Information Processed
   Personal Particulars	Full name, title, age, user ID, gender, address, and date of birth.
   Contact Information	Telephone/mobile number(s), permanent, current and shipping address, state/city of residence, country, pin code, email address.
   Financial Information	Details of Your demat account, active bank account opened on the Platform including account number, Partner Bank and NBFCs customer ID, UPI ID details, Depository account details , salary and income details.
   Identification Information	Know Your Customer (“KYC”) documents including all proofs of identity and address, photograph, Permanent Account Number (PAN), signature, email ID, occupational details, etc.
   Transactional Information (Money Flow)	UPI ID, category and other identifiers along with the details of Offerings on the Platform, mode of payment, location, the date, currency and amount of the transaction, whether the payment was successful, and other information provided by You directly or indirectly to Us or provided to Us by other third party entities. We also store transaction details such as amount spent, transaction ID, date and time of transaction. Further, We may store information relating to Your income, lifestyle levels and usage pattern.
   Usage and Technical Information	IP addresses, application, device or browser type, browser language, referring URL versions and configurations, operating systems, device brand and model, time zone setting, geo-location information, content, visitor details collected in our log files, the pages of our Platform that You visit, unique identifiers associated with Your device(s) and pages that You access on the Platform and the dates and times that You visit the Platform, paths taken and other statistics.
   Investment Information	Information about Your investments and the details of Your Demat Account.
   Marketing and Communication Information	Communications with customer service support, behavioural data (for example, data collected using cookies), information about promotions, surveys, promotional campaigns and records of Your decision(s) to subscribe or to withdraw from receiving marketing materials, if any.
   Information in Your device(s)	We may also access Your contact list, SMS, camera, media files and location data in Your devices for various purposes after seeking necessary permissions.
   Financial SMS Data	We may collect SMS data stored on your mobile device, upon the grant of access by the User. We read and securely store Your SMS data to analyse Your financial profile, process, Your requests, and assess Your financial health to give You the best recommendation.

5. You hereby agree, acknowledge and grant Your consent to Us to obtain information/data from You through the Platform, different communication channels, when You provide Your details in forms, surveys, online applications or similar online fields. Further, You hereby agree, acknowledge and grant Your consent to allow Us to obtain/share Your information/data from/to third-party entities including but not limited to our associate/affiliate entities, relevant Asset Management Companies (“AMCs”), Registrar and Transfer Agents (“RTAs”), KYC Registration Agency (“KRAs”), business partners and financial institutions, to the extent required to provide the Offerings on the Platform, enhance the user experience, build affluence scores/ user insights, analyse data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations.
6. You acknowledge that You are over 18 years of age and are providing Your Personal Information of Your free will.
7. You acknowledge that We may keep records of communications, including phone calls received and made for making enquiries, orders, feedback or other purposes for rendering services effectively and efficiently. The Company will be the exclusive owner of such data and records. You hereby consent and authorize us to publish feedback obtained from You on the Platform. However, all records are regarded as confidential. Therefore, such records will not be divulged to any third party, unless required by law.
8. We will store Your Personal Information at least for a reasonable time from the last date of use of the Offerings on the Platform, the Platform or for such period as may be required by law.

Purpose and Use of Your Data

1. We recognise and acknowledge the value and importance of the protection of Your Personal and Non-Personal Information and ensure that the same will be used for the intended purpose(s). By virtue of this Privacy Policy, We will collect/ receive/ share/ process/ use/ store Your Personal Information and/or Non-Personal Information in accordance with applicable laws to provide You with the Offerings on the Platform, enhance the user experience, manage our relationship with You, build affluence scores/ user insights, analyse data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations, which may inter alia include:
   
   1. Facilitating various Offerings on the Platform provided by Us, including:
      
      1. Setting up Your designated investment account and facilitating the processing of Your investment/redemption instructions which You may initiate through the Platform via Your designated investment account ( "Transaction Instructions" ).
      2. Maintaining a record of Your Transaction Instructions, transactions and holdings, generating and sending reminders, alerts, notifications to You for transactions, upcoming funds transfers, etc.
   2. Verifying Your identity for the purposes of allowing You to avail of the Offerings on the Platform.
   3. Checking/ updating/ registering Your KYC details in centralized KYC databases KRA Databases.
   4. Resolving Your queries, concerns and providing You with support in case of any issues during the use of the Offerings on the Platform.
   5. Informing You about any offers relating to our Offerings on the Platform including sharing of marketing material with You.
   6. Streamlining and customizing Your experience of using the Platform.
   7. Informing You about the progress of and issues with, if any, pertaining to the Transactions Instructions initiated by You and the resolution thereof or relating to the Offerings on the Platform availed by You.
   8. Facilitate the transfer of funds between Your bank account and the bank account(s) of the concerned business partner/affiliate.
   9. Tracking, analyzing and maintaining information about Your use of the Platform.
   10. Carrying out research, planning and statistical analysis.
   11. Undertaking analytics for the purposes of developing or improving our products, Offerings on the Platform, security, service quality, and advertising strategies.
   12. Managing our infrastructure and business operations and complying with internal policies and procedures.
   13. Conducting credit checks, screenings or due diligence checks as may be required under applicable laws, regulations or directives.
   14. Complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities.
   15. Undertaking financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record-keeping activities.
   16. Enforcing obligations owed to Us.
   17. Communicating with our associate/ affiliate entities/ Partner Banks and NBFCs with respect to their products/services that You may have availed through Us.
   18. Enabling Us, the Affiliates and associate/ affiliate entities/ Partner Banks and NBFCs to communicate with You with respect to their products/services that You may have availed by or through Us.
   19. Using Your information in other ways as required or permitted by law or with Your consent.
   20. Collection of data by cookies which helps Us track, analyse and understand Your trends so as to enable Us to understand lacunas (such as slow response time on the Platform) and improve Your interactive experience of using our Offerings on the platform, our design, features and functionalities.
   21. Using Your information to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Terms, breach of our agreement with You or as otherwise required by law.
   22. Disclosing Personal Information about You to our representatives, service providers and other third parties to comply with applicable laws and regulations. We reserve the right to disclose Your Personal Information to third parties in an anonymous or aggregate form, upon the consent of the User, to understand customer trends and patterns and manage and improve our business relationships. We provide Your Personal Information to our business partners, representatives and third-party processors to administer and process for the purposes notified to You in this Privacy Policy, and We may also share such details with third parties (such as auditors or legal advisors) to obtain professional advice. Any such processing will be governed by an agreement in the form required by law, preserving any and all of Your statutory data protection rights. You authorize us to exchange, transfer, share, or part with all or any of Your Personal Information, across borders and from Your country to any other countries across the world with the Affiliates/ agents/ third party service providers/ Partner Banks and NBFCs and financial institutions for the purposes specified under this Privacy Policy or as may be required by applicable law.
   23. Disclosure or transfer of Your Personal Information with Courts and Government agencies in certain instances such as for the verification of identity, or for prevention, detection, investigation, prosecution, and punishment for offences, or in compliance with laws. You hereby consent to the disclosure or transfer of Your Personal Information in these instances.
   24. Disclosure of Personal Information with our other corporate and/or parent/associate entities and the Affiliates to (i) help detect and prevent identity theft, fraud and other potentially illegal acts and cyber security incidents, and (ii) help and detect co-related/related or multiple accounts to prevent abuse of Offerings on the Platform.
   25. Disclosure of KYC information to the Company/ the Affiliates/ and other affiliate entities or any other subsidiary company of the Company, that may be incorporated in the future for the purpose of verification and transfer of units. By agreeing to the terms and conditions You are hereby authorizing Us to share the KYC details with the Company, the Affiliates and other affiliate entities or any other subsidiary company that may be incorporated under the Company, upon the consent of the User.
2. You understand, acknowledge and expressly grant Us Your consent:
   1. To share/ receive Your Personal Information and/or Non-Personal Information with/from Us/ affiliate entities/ business partners, for the purposes which are not limited to providing You with the Offerings on the Platform, improving the existing Offerings on the Platform, enhancing the user experience, building affluence scores/ user insights, outsourcing relationship management activities, analysing data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations.
   2. To share Your Personal Information and Non-Personal Information with the companies that We plan to merge with or entities that We may acquire or be acquired by subject to the provisions of applicable law, in which situation We will require that the new combined entity or the acquired/ acquiring entity follows this Privacy Policy with respect to Your Personal Information.
   3. To collect/ receive/ process/ use/ store certain Personal Information (including PAN, date of birth, residential status, etc.) that You may have shared with the Company or the Affiliates or any other subsidiary company that may be incorporated in the future, in order to allow Us to provide the Offerings on the Platform to You. Further, You expressly consent that certain Personal Information that may be shared by You with Us, including financial information (such as debit card details or other payment mode details), or Your information that may be collated by Us from the KRAs may be shared with the Company, the Affiliates, the Partner Banks and NBFCs and affiliate entities or any subsidiary company that may be incorporated in the future, in order to facilitate the provision of our Offerings on the Platform to You.

Links to Other Sites

1. Links to third-party advertisements, third-party websites/ applications/ products/ services or any third-party electronic communication service (“Other Websites”) may be provided on the Platform which is operated by third-party entities and is not controlled by, or affiliated to, or associated with Us unless expressly specified on the Platform.
2. We are not responsible for any form of transmission, whatsoever, received by You from any third-party website. Accordingly, We do not make any representations concerning the privacy practices or policies of such third-party entities or terms of use of such Other Websites, nor do We control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such Other Websites. The inclusion or exclusion does not imply any endorsement by Us of the Other Websites, the websites provider, or the information on such Other Websites. The information provided by You to such Other Websites shall be governed in accordance with the privacy policies of such Other Websites, and it is recommended that You review the privacy policy of such Other Websites prior to using such websites.

Data Retention

Notwithstanding anything to the contrary mentioned elsewhere in the Privacy Policy, We may store/retain Your Personal and Non-Personal Information for as long as the same is required for the fulfilment of purposes for which We collected it. The retention of Your Personal Information and/or Non-Personal Information by Us is determined by considering compliance with legal (contractual, statutory or regulatory requirements), accounting and compliance reporting requirements. Retention of Your Personal Information and/or Non-Personal Information will also be applicable pursuant to cancellation/ deactivation/ non-subscription of Your designated investment account with Us.

Your Rights

1. We seek to provide reasonable assistance to cater to request(s) from You regarding the processing of Your Personal Information and the right to amend and withdraw permission to the processing/ use/ storing/ sharing of Your Personal Information. In accordance with applicable laws and as per the terms of this Privacy Policy, You may exercise the following rights:
   
   1. Access the information We hold about You, or get a copy of it in a portable (machine-readable) format or request Us to send it to a third party.
   2. Review or rectify the inaccurate Personal Information stored with Us.
   3. Withdraw Your consent to collect/ receive/ share/ process/ use/ store Your Personal Information that You had given Us for availing the Offerings on the Platform and prevent further processing of Your Personal Information subject to the terms of this Privacy Policy. You may also withhold Your consent prior to the collection and processing of Your Personal Information and Non-Personal Information.
   4. Ask Us to update/delete Your Personal Information. However, You understand that the deletion of certain information may impact the Offerings on the Platform being offered to You and the same may result in total suspension of the Offerings on the Platform if the deleted information is of a category that is considered mandatory to provide the Offerings on the Platform.
   5. Some of our Offerings on the Platform allow You to upload, submit, store, send or receive content. When You upload, submit, store, publish, send or receive content to or through our Offerings on the Platform, You provide us with Your consent to utilise such content, including for our marketing purposes, subject to our Privacy Policy.
      Such content must not:
      
      1. Be harmful, harassing, blasphemous, defamatory, obscene, pornographic, paedophilic, libellous, invasive of another’s privacy, hateful or racially or ethnically objectionable, disparaging, and relating to, or encouraging money laundering or gambling
      2. Harm minors in any way.
      3. Infringe any patent, trademark, copyright or other intellectual property rights.
      4. Deceive or mislead the reader about the origin of such messages or communicate any information that is grossly offensive or menacing in nature.
      5. Contain software viruses or any other programs designed to interrupt, destroy or limit the functionality of another computer or mobile device.
      6. Threaten the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign states, or public order.
      7. Cause the incitement to commit any offence or prevent the investigation of any offence.
      8. Be insulting to any other nation.
      9. Impersonate another person.
      10. Violate the provisions of the Information Technology Act, 2000 and rules and regulations thereunder or any other applicable laws.
2. You can exercise any of the aforementioned rights by submitting a request to [email protected]
3. You understand that these rights are limited in some situations, such as, where We are legally or otherwise bound to process/ retain/ share/ disclose Your Personal Information. This may also affect our ability to provide You Offerings on the Platform and therefore may lead to discontinuation of the Offerings on the Platform You avail from the Platform.

Security Precautions

1. We work to protect the security of Your Personal Information during transmission by using appropriate software, which encrypts the information You input. This encrypted information is stored on secure servers and data centres. Further, We ensure that the number of employees involved in the management of the data centre who have physical access to these computers is limited. Also, We use advanced security technology to prevent our computers from being accessed by unauthorized persons.
2. We have also implemented information security practices and standards and have in place information security programmes and policies containing managerial, technical, operational and physical security measures that are in compliance with the applicable laws including, so as to protect the information provided to Us from unauthorized access, use, modification, damage, disclosure or impairment. Further, We may from time to time use reasonable additional or alternative procedures to ensure the security and confidentiality of Your Personal Information through our Platform.
3. Notwithstanding the above, We are not responsible for the confidentiality, security or distribution of Your Personal Information by third parties outside the scope of our agreement with such third parties. Further, We will not be responsible for any breach of security or for any actions/omissions of any third parties or events that are beyond our reasonable control, including but not limited to, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service or telephone service of the User etc.
4. No data transmission over the Internet is fully secure, so You acknowledge that We cannot ensure or warrant the security of any information You submit to us. Further, We do not guarantee in any way, the security of any information that You transmit or share on the Platform; and You do so at Your own risk.

Disclaimer of Information

You are responsible for maintaining the accuracy, truthfulness, correctness and completeness of the Personal Information You provide Us, the Affiliates and our associate/affiliate entities/ Partner Banks and NBFCs, that is necessary for providing the Offerings on the Platform to You. You shall hold harmless and indemnify Us, the Affiliates and our associate/affiliate companies/ Partner Banks and NBFCs from and against all claims arising out of or in relation to the wrongful Personal Information provided by You to Us, the Affiliates and our associate/ affiliate entities/ Partner Banks and NBFCs. If Your Personal Information is wrong/inaccurate, You shall correct, delete inaccuracies, or amend Your information by making the necessary change on the information on the Platform or contact us at [email protected]

Changes to Privacy Policy

We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, We shall update the same on the Platform. Please revisit the Platform periodically for the latest information on our privacy practices. Once posted, those changes are effective immediately unless stated otherwise. Continued access or use of the Platform or availing of the Offerings on the Platform constitutes Your acceptance of the changes to the amended Privacy Policy. However, if You do not agree with the changes, please do not continue to use the Platform or avail of the Offerings on the Platform or submit Your Personal Information to Us and notify Us about Your disagreement over an email [email protected] . Subsequently, upon confirmation from the Company, Your access to the Platform will be suspended.

Contacting Us

In accordance with Information Technology Act 2000 and rules made thereunder, the name and contact details of the Grievance Officer are provided below for Your reference
Name: Pranav Iyer
Email: [email protected] or [email protected] or [email protected]
Address: Third floor, Block A, Stable Money, Bhive HSR Premium Campus, Krishna Reddy Industrial Area, Kudlu gate, Bommanahalli, Bangalore, Karnataka, India, 560068