PRIVACY & COOKIES

Earnnest Online Privacy Notice

Updated: 23 Jan 2022

This privacy policy (“Privacy Policy”) will inform the users of the Website as to how Earnnest collects, handles, stores, processes and protects the personal information of users of the Website  when they visit the Website (regardless of where they visit it from) (available at: www.earnnest.me; and tell you about your privacy rights and how the law protects you. If you reside outside India, your information will be handled, processed, stored, used, stored and shared as per applicable Indian privacy laws and standards. For the purpose of this Privacy Policy, wherever the context so requires “you” or “your” shall mean User and the term “we”, “us”, “our” shall mean Earnnest.

This Privacy Policy should be read along with the Terms & Conditions of the Website (available at: www.earnnest.me). Your information is collected by us at the time of your access or browsing of the Website, registration on the Website, or any other action taken by you on the Website. It is important that you read this Privacy Policy together with any other notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. This Privacy Policy supplements any and all other such notices and is not intended to override them.

All words and expressions used and not defined in this Privacy Policy shall have meanings assigned to them in the Information Technology Act, 2000, the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 and the Terms and Conditions.

  1. INFORMATION WE COLLECT ABOUT YOU AND MANNER OF COLLECTION

Personal Data means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available, is capable of identifying such natural person. Personal data does not include anonymized or aggregated data which cannot identify an individual. Personal data consists of ‘sensitive personal data or information’ which consists of financial data and information relating to a natural person. We may collect, use, store and transfer the following types of Personal Data which is voluntarily provided by you:

  • Personal and business contact information including name, postal and email address, Aadhaar number and telephone/mobile number;
  • Tax status (pan card, tax ID, tax residence);
  • Financial data (assets, investor profile, credit history, bank account details, demat account details, debts and expenses);
  • Other background data(information on unlawful conduct/criminal history) and
  • Technical dataincluding internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.

By providing your Personal Data, you consent to our use of your Personal Data in accordance with this Privacy Policy. You can withdraw your consent to our use of your Personal Data, at any time, by writing to Earnnest’s Privacy Officer (as per details provided below). If you withdraw your consent to our use of your Personal Data, Earnnest shall not be obligated to provide its services to you or permit you to access our Website. 

  1. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions: You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
  • Website use and registration: Personal Data may be provided by you, as appropriate, when contacting Earnnest through the Website.
  • Automated technologies or interactions

Information automatically collected: As you interact with our Website, we may automatically collect certain information of technical nature including, without limitation, your internet protocol (“IP”) address, information about the equipment on which you access the Website, information about the browser, operating system, and your browsing actions and patterns, to improve the user experience on the Website. Automatic collection of such information is facilitated with the use of “cookies”, server logs and/ or other similar digital tools for collection of such information. We may also receive such information about you if you visit other websites employing our cookies. Please note that use of cookies or similar digital tools for collection of such information by us does not result in gaining access to information that is capable of personally identifying you, i.e. Personal Information/ Sensitive Personal Data. You can opt to refuse all or some browser cookies when prompted on our Website about our use of cookies. If you disable or refuse our use of cookies, please note that all or some parts of this Website may become inaccessible or not function properly.

Information collected from other sources: Other than the information you grant us directly, we may also gain access to your information from third-parties you have provided your information to and who we have partnered with for the provision of services to you on the Website. We may also gain access to your information from publicly available sources. 

  1. ACCURACY OF PERSONAL INFORMATION

You are solely responsible for ensuring that the Personal Information/ Sensitive Personal Data provided by you is accurate, up-to-date and complete. You shall have the right to review your Personal Information/ Sensitive Personal Data provided to us at the time of registration and from time to time on the ‘My Account’ section of the Website and update the same in the event of any change.  Earnnest shall not be responsible for ensuring authenticity of the Personal Information/ Sensitive Personal Data supplied by you. Earnnest will also not be liable for any issues arising out of inaccurate or incomplete Personal Information/ Sensitive Personal Data provided by you.   

  1. USE OF INFORMATION COLLECTED

We will only use your information for reasonable and legitimate purposes including in the following circumstances:

  1. For the performance of a contract already / to be entered into with you and providing the requisite services to you;
  2. When necessary for our legitimate business interests (or those of a third party), where your interests and fundamental rights do not override those interests;
  3. To improve our Website in order to better serve you;
  4. To allow us to better service you in responding to your inquiries/ grievances in relation to the Website and/ or the services provided by us on the Website;
  5. For compliance with a judicial, administrative, governmental or regulatory obligation;
  6. For internal compliance audits;
  7. For developing our products and services;
  8. For conducting research or surveys.
  9. To send marketing as well as non-marketing commercial communications to you.

We will only use your information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is incidental to the original purpose. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

  1. THIRD PARTY WEBSITES

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit. 

  1. COOKIES

Cookies help provide functionality to the Website and help us analyse Website usage more accurately. Technical information collected through the Website is used to analyse and report on website traffic, usage trends, for security purposes, and to improve Earnnest’s online content and services. Earnnest may use third party analytics tools to analyse website traffic and improve the site, based on information collected by cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that all or some parts of this Website may become inaccessible or not function properly.

  1. DISCLOSURES OF YOUR PERSONAL INFORMATION

Earnnest does not disclose information to third parties for any purpose, including, without limitation, commercial purposes; and does not sell, trade or transfer such information. The information, including Personal Information/ Sensitive Personal Data collected by us may, however, be shared with such third parties whose services are necessary for servicing you in respect of your investment without your consent.

We may share your Information with a third-party other than one whose services are necessary for servicing you, without obtaining your prior consent in the following circumstances:

  • Upon request or requirement by applicable law, or any judicial, administrative, regulatory or governmental authority/ agency;
  • In the event sharing of your Information is required to enforce or protect our rights or any of our affiliates, associates, employees, directors or offers or when we have reason to believe that disclosing your Information is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or our Website and/ or services on the Website;
  • For the purpose of advertising our services to our current or prospective business partners and/ or to assist our advertisers/ business partners in understanding our users and the usage of the Website. However, in such an event, no personally identifiable information, i.e. your Personal Information/ Sensitive Personal Data will be made available.

For provision of services on the Website, Earnnest may disclose your information to third-party service providers or partners in order to provide a service for which we have integrated with such third-party service providers/ partners and you hereby provide your consent in this regard. We require all third parties to respect the security of your Personal Data and to treat it by the same standards of data security practices and procedures as we are under law and contract. We do not allow our third-party service providers to use your information for their own purposes and only permit them to process your information for specified and necessary purposes and in accordance with our instructions. The processing of your information by these third parties may involve a transfer of data outside the country in which the information was originally provided. Such third parties are not permitted to further disclose your information to anyone else. 

  1. HOW WE PROTECT PERSONAL INFORMATION

We have put in place appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Our security practices and procedures are in compliance with the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.

We limit access to your information to employees, agents, contractors and other third parties strictly on a ‘need to know’ basis. The recipients of your information will only process your information on our instructions and are subject to a duty of confidentiality.

Earnnest takes steps to ensure the security of your information, regardless of the format in which it is held, while in its custody is appropriate to the sensitivity of the information. Our physical security measures include, without limitation, the use of locked cabinets and storage facilities and our technical security measures , include, without limitation, appropriate encryption of stored Information, use of passwords to protect the stored Information on our database

Earnnest also takes appropriate steps to protect your information disclosed to third parties, such as by way of contractual agreements stipulating the confidentiality and security of the information and the purpose for which it is to be used. Security standards maintained by such third parties are equivalent to those of Earnnest and commensurate with market practice.

Please be aware that, although we have implemented appropriate security measures to provide security for your information, no security system can prevent all potential security breaches and hence, we cannot guarantee the security undertaken by us. We will however endeavour to modify our Privacy Policy from time to time to incorporate any necessary changes to protect and secure your information better. 

  1. PERSONAL INFORMATION TRANSFER

There may be instances when we need to transfer your information to recipients outside India, in the event such transfer is necessary for the purpose of provision of services by us to you, or where your prior consent has been obtained in this regard. We shall ensure that your information is only transferred to a recipient located in a country that ensures the same level of data protection that is adhered to by us in India under the applicable data privacy laws. 

  1. HOW LONG WILL YOU USE MY INFORMATION FOR?

We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. You may at any time revoke or withdraw your consent to provide information to us by contacting the grievance officer whose details are provided below. However, revocation of consent to retain information may result in our inability to provide services on the Website to you. You agree that Earnnest shall be held harmless from any complaints, legal proceedings or claims filed or initiated by you and / or any other persons in case of deficient services or absence of services from our end to you on account of revocation of consent for use of your Information by you. 

  1. REVISION OF PRIVACY POLICY

We reserve the 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 Website. Users should periodically review this page for the latest information on our privacy practices. Once posted, those changes are effective immediately, unless stated otherwise. Continued access or use of the Services constitutes your acceptance of the changes and the amended Privacy Policy. In the event the Privacy Policy or any terms of the Privacy Policy are not acceptable to you, you may opt to stop using the Website and the services provided on the Platform and contact us on the details provided hereunder to revoke your consent granted to us for collection, storage and processing of your personal information.

In case you wish to no longer use the Website and the services provided on the Website for any reason whatsoever, you may revoke the consent granted to us for collection, storage and processing of your personal information by contacting us on the details provided hereunder. Please note that your personal information will be retained with us for as long as you use the Website and/ or the services provided on the Website or for such period as may be necessary under applicable law. 

  1. INQUIRIES

If you have any questions about the Privacy Policy, you may contact the grievance officer as per the details given hereinbelow. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding the use of your personal information and/ or sensitive personal data or information. 

  1. GRIEVANCE OFFICER

In accordance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the name and contact details of the grievance officer are provided below. You may contact the Grievance Officer to address any discrepancies and grievances you may have with respect to your information held by us. The grievance officer will redress your grievances expeditiously.

Name: Puja Khandelia

Contact Number: + 91 22 67022911

Email ID: puja.khandelia@earnnest.me

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

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