Privacy Policy
Angel One Wealth Limited (formerly known as Angel One Wealth Management Limited), a Public Limited Company incorporated under the Companies Act, 2013 (hereinafter referred to as "AOW" or "the Company") having its registered office at 601, 6th Floor, Ackruti Star, Central Road, MIDC, Chakala, Andheri (East), Mumbai – 400 093, Maharashtra, India, which owns and operates the web-based platform https://www.ionic.in/ and mobile-based application 'Ionic Wealth by Angel One' along with Angel One Investment Managers & Advisors Private Limited which operates the web-based platform and mobile-based application and Angel One Investment Services Private Limited which operates the web-based platform and mobile-based application (collectively the "Platform"), are committed to protecting your privacy and the information that you share while using the Platform. We value the trust you place in us. That's why we maintain the highest security standards for securing the transactions and your information.
This Privacy Policy governs the manner in which information is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company and its Affiliates. It is hereby clarified that for the purposes of this Privacy Policy, the Terms "we" or "us" or "our" shall mean the Company and/or its Affiliates and, wherever the context so requires the term "You" or "User" shall mean any natural or legal person including online and offline investors. This Privacy Policy does not apply to information that you provide to us or is available in public domain, or that is collected by, any third-party through the Platform, and any Third-Party Sites that you access or use in connection with the services offered on the Platform.
Please read the Privacy Policy carefully prior to using or registering on the Platform or accessing any material, information or availing any services through the Platform.
By clicking on the "I accept" button provided at the signup page, you accept this Privacy Policy ("Privacy Policy") and our Terms of Use ("Terms") and agree to be legally bound by the same. This Privacy Policy is incorporated into and subject to our Terms. All capitalized Terms used and not defined in this Privacy Policy shall have the meaning ascribed to them under the Terms.
This Privacy Policy (i) is an electronic record under all applicable nationally binding data protection or such other statutes, laws, secondary legislation or regulations, and common duties (as maybe applicable) pertaining to privacy, confidentiality and/or the protection of data including the Information Technology Act, 2000 and rules thereunder and the Digital Personal Data Protection Act, 2023 (as applicable) ("Applicable Laws") and is generated by a computer system; and (ii) will not require any physical, electronic, or digital signature.
We view protection of your privacy as a very important principle. We understand clearly that You and Your Personal Information is one of our most important assets. We store and process Your Information including any sensitive financial information collected (as defined under the Act), if any, on computers that may be protected by physical as well as reasonable technological security measures and procedures in accordance with Act and rules made there under. If You object to Your information being transferred or used in this way, please do not provide the details of your information on the Platform.
1.
Collection of Information
This Privacy Policy applies to the following information:
1.1
Information you give us: You may provide certain information to us voluntarily while signing-up on the Platform or for availing services on the Platform such as name, mobile number, Permanent Account Number (PAN), signature, email address, date of birth, gender, photograph (selfie), marital status, communication and residential address details. We may also require you to provide additional information such as proof of address, residence ownership type, location, annual income, employment type, and source of income, number of years in employment, employer name, employer address, designation, official email address, business name, business address, nature of business, and additional income source and risk appetite. We may also collect your signature and also take your live video or live selfie photo at the time of sign up for verification purposes. We may also collect other related information such as the date and time of contact with you, the number of attempts and your availability, for the said verification. Additionally, we may also ask you for your personal preferences such as your choice of music, travel destinations and such other information as may be explicitly communicated to you from time to time through the Platform. The information collected in the course of your verification shall solely be used for creating your profile on the Platform and for authenticating your transactions on the Platform;
1.2
We may also ask you for certain financial information, including your bank account details and type, Indian financial system code (IFSC) of bank, and/or other necessary payment related details or other payment method data which may be necessary for the Company or its Affiliates to render Services to you. We will obtain your explicit consent in compliance with before collecting such information from you. We may ask you to provide certain additional information about yourself on a case-to-case basis, subject to obtaining your explicit consent in accordance with applicable laws. The purposes for which such additional information will be used will be communicated to you at the time of seeking the additional information. All information disclosed by you shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity / genuineness / misrepresentation / fraud / negligence of the information disclosed shall lie on the Company or its Affiliates nor will the Company or its Affiliates be in any way responsible to verify any information obtained from you;
(the above information in paragraphs 1.1 and 1.2 is collectively referred to as "Personal Information").
1.3
KYC related information: Where required under Applicable Laws for the provision of Services by the Company or its Affiliates, in addition to the Personal Information provided to us, we may retrieve from your records available with third party including from Know Your Customer (KYC) Registration Agency (KRA) such as name, KYC details, KYC status, father's/spouse's name, occupation, address details and other related documents, for completion of your KYC;
1.4
Location based information: When and if you download and/or use the Platform through your mobile, we explicitly seek permissions from you to get the required information from the device. We may receive information about your location, your IP address, and/or your mobile device, including a unique identifier number for your device and such other information as may be required for onboarding you on the Platform (through a one-time permission to access and process such information at the time of onboarding and KYC collection). In addition to the above, we identify and use your IP address to also help diagnose problems with our server, resolve such problems and administer the Platform. Your IP address is also used to help identify you and to gather broad demographic information.
1.5
Access to Camera and Microphone: We require a one-time access to your camera to scan and capture the required KYC documents thereby allowing us to auto-fill relevant fields. As a part of facilitation of the KYC process, we require a one-time access to your camera to enable you to initiate your KYC process. This permission allows us or our authorized agents to perform your video KYC while also taking screenshots of your original officially verified documents that you present during your video KYC. Video KYC enables you to complete your KYC digitally, smoothly, and efficiently. Your video shall be recorded and retained for regulatory purposes along with the screenshots of original official verified documents. We require a one-time microphone permission to enable a two-way communication between our authorized agent and you for the purpose of performing and completing your video KYC. Your audio shall be recorded where required for regulatory purposes.
1.6
Access to storage: We require storage permission so that your KYC and other relevant documents can be securely downloaded and saved on your phone. You can then easily upload the correct KYC related documents for faster financial product application details filling process. This ensures that you are provided with a seamless experience while using the Platform. This is a one-time request and the same would be obtained at the time of sign up.
1.7
Non-Personal Information: We may also collect certain non-personal information, such as system generated user ID and access tokens ("Non - Personal Information") while you browse, access or use the Platform or if you have the Company's mobile application downloaded on your device. We receive Non–Personal Information by the use of data collection devices such as "cookies" on certain pages of the Platform, in order to help and analyse our web - page flow, track user trends, and promote trust and safety. We may place both permanent and temporary cookies on your device. We also use cookies to allow you to enter your password less frequently during a session on the Platform. Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case, you may not be able to use certain features or Services being provided on the Platform or you may be required to re-enter your password each time you log – in or access the Platform during a session.
1.8
User communications: If you choose to post messages on our message boards, chat rooms or other message areas or leave feedback, we will collect and store such information you provide to us. We retain this information as necessary to resolve disputes, provide customer support, respond to queries, and inquires, and troubleshoot problems and improve the Services. If you send us correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Platform, we may collect and retain such information into a file specific to you for responding to your request and addressing concerns in relation to your use of the Platform.
(all information collected by us as detailed in paragraphs 1.1 to 1.8 above shall constitute your "Personal Data").
2.
Personal Data Collection Practices
2.1
All financial information gathered by us shall be stored on servers, log files and any other storage system owned by the Company or its Affiliates or by third parties in India and such storage will be need-based and to the extent required to render services.
2.2
While we are responsible under Applicable Laws in India to ensure completeness, accuracy and consistency of your Personal Data, we cannot comply with this obligation without your due co-operation. You acknowledge and agree that you are responsible for ensuring that the Personal Information you provide is accurate, complete and current and that you will co-operate with us to ensure that such Personal Information is complete, accurate and consistent till such time such Personal Information is processed by us.
2.3
Our primary goal is to provide you a safe, efficient, smooth, and customized experience on the Platform. The information collected allows us to provide the services and features on the Platform that most likely meet your needs, and to customize the Platform to make your experience safer and easier. More importantly, while doing so, we collect the above-mentioned Personal Data that we consider necessary for achieving this purpose.
2.4
As a matter of principle, we do not collect any special categories of Personal Data about you such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health or any genetic information. If we are required to collect any such information for rendering Services, we will do so only after obtaining your explicit consent through the Platform.
2.5
We also do not voluntarily or actively collect, use or disclose Personal Data of minors according to the minimum age equivalent in the relevant jurisdiction or of persons with disability, without the prior verifiable consent of the parents or guardians of the minor, as required under Applicable Laws. If we learn that we have collected the Personal Data of a minor, without first receiving a verifiable parental consent, we will take steps to delete the information in a manner consistent with Applicable Laws of India as soon as possible.
2.6
We may obtain some of your information including Personal Data from third parties, or from publicly available sources. This Privacy Policy shall not apply to any information including your Personal Data made publicly available by you. The third parties from who we obtain your information include our business partners, independent service providers, our group entities, various merchants, marketplaces, re-sellers, banks, payment partners, payment aggregators, payments systems, payment service providers, financial institutions and from credit reference agencies and credit bureaus on your behalf. You hereby provide your consent for us to do so subject to the Applicable Law for the time being in force.
2.7
In general, you can browse the Platform without telling us who you are or without revealing any Personal Information about yourself. In such a case, we will only collect and store the Non – Personal Information. Wherever possible, while providing the information to us, we indicate which fields are mandatory and which fields are optional for you. You always have the option to not provide the Personal Information to us through the Platform by choosing to not use a particular Service or feature being provided by us on the Platform, which requires you to provide such information. We may automatically track certain information about you based upon your behaviour on the Platform. We use this information to do internal research on your demographics, interests, and behaviour to better understand, protect and serve you. This information is compiled and analysed by the Company and/or its Affiliates on an aggregated basis and not individually, in a manner that does not specifically identify you. However, please note that we do not track the behaviour of persons who are minors (i.e., persons below the age of 18 years).
2.8
You also agree that all the information shared by you with the Company and/or its Affiliates is lawful, true and correct and does not violate or infringe any laws. In case of any violations, infringement, furnishing of wrongful or unauthorized information, the Company and/or its Affiliates shall not be liable to you or to any third party for the same.
2.9
You acknowledge that if we determine that any information you have provided or uploaded violates the Terms of this Privacy Policy, we have the right, in our absolute discretion, to delete or destroy such information without incurring any liability to you.
3.
Use of Information
3.1
We use the Personal Data for the following purposes
(1)
to create your login credentials or for creating your profile on the Platform;
(2)
to provide and improve the Services and features on the Platform that you request;
(3)
to resolve disputes and troubleshoot problems;
(4)
to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users;
(5)
to inform you about online and offline offers, products, services, and updates;
(6)
to analyse your online behaviour to customize and enhance your experience on the Platform;
(7)
to share marketing materials with you;
(8)
to detect, prevent and protect us from any errors, fraud and other criminal or prohibited activity on the Platform;
(9)
to enforce and inform about our Terms and conditions;
(10)
to process and fulfil your request for Services or respond to your comments, and queries on the Platform;
(11)
to contact you;
(12)
to allow our business partners including third-party Partners to present customized messages and/or promotional or marketing materials to you;
(13)
to enable us to avail services from third party service providers to enhance and customize your experience on the Platform;
(14)
to communicate important notices or changes in the Services provided by the Company and/or its Affiliates or third-party Partners, use of the Platform and the Terms which govern the relationship between you and us; and
(15)
for any other purpose after obtaining your explicit and unambiguous consent at the time of collection.
3.2
We shall not retain or store that information for longer than is required for the purposes except when the Personal Data may lawfully be used or is otherwise required under any other law for the time being in force. The Personal Data collected shall be used for the purpose for which it has been collected. By agreeing to avail the service offered by Us you have agreed to the collection and use of your Personal Data by Us.
3.3
You also specifically agree and consent to us collecting, transferring, and sharing Personal Data (including Personal Information) related to you among the Company and its Affiliates or to third-party partners or such other third-parties as may be listed out here. We will take your specific consent in case we wish to share your Personal Data with any other third party other than those aforementioned and update the aforementioned list.
3.4
We may occasionally ask you to complete optional online surveys. These surveys may ask you for your contact information and demographic information (like zip code, age, or income level). We use this information to 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. We use your Personal Data to send you promotional emails, however, we will provide you the ability to opt-out of receiving such emails from us. If you opt out, the Company and/or its Affiliates may still send you non-promotional emails, such as emails about the services and your transactions on the Platform. Unless and until, you explicitly give your consent to us, to do so, we will not share your Personal Data with another user of the Platform and vice versa.
3.5
Notwithstanding anything contained herein, the Company and/or its Affiliates may, in compliance with Applicable Laws in India, process your Personal Data without obtaining your consent in the event: (a) you have voluntarily provided your Personal Information to the Company and/or its Affiliates, and have not indicated that you do not consent to the use of such Personal Data by us; (b) the purpose is for fulfilling any obligation under any law for the time being in force in India on any person to disclose any information to the State or any of its instrumentalities, subject to such processing being in accordance with the provisions regarding disclosure of such information in any other law for the time being in force; (c) the purpose is for compliance with any judgment or decree or order issued under any law for the time being in force in India, or any judgment or order relating to claims of a contractual or civil nature under any law for the time being in force outside India; (d) the purpose is for responding to a medical emergency involving a threat to the life or immediate threat to the health of the user or any other individual; (e) the purpose is for taking measures to provide medical treatment or health services to any individual during an epidemic, outbreak of disease, or any other threat to public health; or (f) the purpose is for taking measures to ensure safety of, or provide assistance or services to, any individual during any disaster, or any breakdown of public order.
3.6
When You register with or view our site, our servers automatically record certain information that your web browser sends whenever you visit our Platform. The kind of information that is gathered automatically includes the type of browser you are using (e.g. Internet Explorer, Firefox, etc.), the type of operating system you are using (e.g. Windows or Mac OS) and the domain name of your internet service provider, the date and time of your visit and the pages on our website. We sometimes use this information to improve our website(s) design, content and primarily to give you a better browsing experience.
3.7
This notice / policy is not intended to and do not create any contractual or other legal rights in favour of any user or viewer of this website or on behalf of any other party. However, users and viewers are informed that by using the website, they are deemed to have consented to the collection and use of information by Us as stated above.
4.
Access And Sharing of Information
4.1
Access to your Personal Data will be provided to certain of our employees strictly on a need-to-know basis. You hereby agree to and provide your free, specific, explicit and unambiguous consent to allow the Company and its Affiliates (to the maximum extent permissible under Applicable Laws) to collect, store, process and share your Personal Data among themselves and to share the same with third-party partners, third-party vendors, consultants, and other service providers who work for the Company or its Affiliates. The disclosure of your Personal Data to third parties may be required for instance, to provide you services or to enable your access of services or products provided by third-party partners, for processing payments including validation of your bank accounts, facilitate or assist in our marketing and advertising activities, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to services etc. Please note that we do not disclose your Personal Data to third parties for their marketing and advertising purposes without your explicit consent.
4.2
The Company or its Affiliates may disclose your information to the extent necessary: (i) to comply with Applicable Laws and to respond to lawful requests and legal process, (ii) to protect the rights and property of the Company and/or its Affiliates, our users, and others, including to enforce the Terms, and (iii) in an emergency to protect the personal safety and assets of the Company and/or its Affiliates, the users, or any person. In such an event the Company and/or its Affiliates are in no manner responsible for informing you or seeking your approval or consent.
4.3
We may, in compliance with Applicable Laws, share/transfer/assign all of your Personal Data and other information with any other business entity(ies), in the event of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of our business.
4.4
You may upon written request to us review the Personal Data provided. We shall ensure that any Personal Data found to be inaccurate or deficient shall be corrected or amended as feasible.
5.
Security and Precautionary Measures
5.1
The Company and its Affiliates have reasonable security measures and safeguards in place to protect your privacy and Personal Data from loss, misuse, unauthorized access, disclosure, destruction, and alteration of the information in compliance with Applicable Laws. We cannot, however, ensure or warrant the security of any information you transmit to the Company and/or its Affiliates or guarantee that your Personal Data may not be accessed, disclosed, altered, or destroyed by a breach of any of our security measures and safeguards. In the event of any actual or suspected security incident, including data breach, we will take all measures required to be undertaken under Applicable Laws. It is further clarified that you have the obligation to ensure, so long as you access and/or use the Platform (directly or indirectly), that you take adequate physical, managerial, and technical safeguards at your end to preserve the integrity and security of your information (including your Personal Information).
5.2
Additionally, we shall also ensure compliance with various technology standards/requirements on cybersecurity stipulated under Applicable Laws, in provision of our services to you.
5.3
Once we receive your transmission of information, We make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. To protect your privacy and security, We take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Us, at all times.
6.
Links to Third Party Sites and Collection of Information
6.1
Our Platform may provide links to other third - party platforms including those of third-party Partners ("Third – Party Sites") that may collect your Personal Data such as your IP address, browser specification, or operating system, etc. The Company and/or its Affiliates are not in any manner responsible for the security of such information or their privacy practices or content of those Third – Party Sites. Additionally, you may also encounter "cookies" or other similar devices on certain pages of the Third – Party Sites and it is hereby clarified by the Company and its Affiliates that they do not control the use of cookies by these Third-Party Sites. These third-party service providers and Third-Party Sites may have their own privacy policies governing the storage and retention of your information that you may be subject to. We recommend we are not liable for the information published in search results or by any Third-Party Sites.
7.
Public Posts
7.1
You may provide your Feedback reviews, testimonials, etc. on the Platform on your use of Services use of the Services provided by the Company ("Posts"). Any content or Personal Information and Posts that you share or upload on the publicly viewable portion of the Platform (on discussion boards, in messages and chat areas, etc.) will be publicly available, and can be viewed by other Users. Your Posts shall have to comply with the conditions relating to Use of Platform as mentioned in the Terms. The Company shall have the unconditional right to remove and delete any Post or such part of the Post that, in the opinion of the Company, does not comply with the conditions in the Terms. The Company reserves the right to use, reproduce and share your Posts for any purpose. If you delete your Posts from the Platform, copies of such Posts may remain viewable in archived pages, or such Posts may have been copied or stored by other Users.
8.
Your Rights and Changes to Privacy Policy
8.1
Withdrawal of consent: You may choose to withdraw your consent (including regarding processing of data by us or by any third party or regarding data retention) provided hereunder at any point in time. Such withdrawal of the consent must be sent in writing to compliance@ionic.in In case you do not provide your consent or later withdraw your consent, we request you not to access the Platform and use the services. The Company and/or its Affiliates shall reserve the right not to provide services to you in the instance you do not provide your consent in the manner set out in this Privacy Policy or the Terms or if withdraw your consent in the manner provided herein. Where you withdraw the consent provided by you, the Company and/or its Affiliates may delete your information (personal or otherwise) unless otherwise required under Applicable Laws.
Further, the Company and/or its Affiliates may also de-identify it so that it is anonymous and not attributable to you.
Managing Your information and Correcting inaccuracies in the information: You may correct or update any information, including your Personal Information online. You also have a right to (a) ask us for a summary of Personal Data being processed by us and the processing activities undertaken by us with respect to such Personal Data; (b) the identities of all other third-party entities with whom your Personal Data has been shared by us along with a description of the Personal Data so shared, except when such sharing is pursuant to a written request by such entity who obtains the information for the purpose of prevention or detection or investigation of offences or cyber incidents, or for prosecution or punishment of offences. You have the right to ask us to correct inaccurate or incomplete or misleading Personal Information concerning you or update your Personal Information (which you cannot update yourself online) by contacting us at compliance@ionic.in In the event of loss of access details, you may retrieve the same or receive new access details by sending an e-mail to: compliance@ionic.in
8.2
Right of Erasure: This is also known as 'the right to be forgotten' and, in simple Terms, enables you to request the deletion or removal of your Personal Data where there's no compelling reason for us to keep it. Such right of erasure can be exercised by writing to us at compliance@ionic.in On such a request for erasure, we shall delete all your Personal Data stored by us and will apply best efforts to require any third-party service provider processing your Personal Data on our behalf deletes all your Personal Data. This is not a general right to erasure; there are exceptions, such as when the law requires us to retain certain personal information about where such retention is required for providing our services to you or where such retention is required for providing our services to you.
8.3
Right to Nominate: You shall have the right to nominate, in a manner prescribed by the relevant Government Authority any other individual, who shall, in the event of your death or incapacity, exercise your rights in accordance with Applicable Laws.
8.4
Use of a Consent Manager: You are permitted to give, manage, review or withdraw your consent provided to us to process your Personal Data through a 'consent manager'. A consent manager is an entity that is registered with the relevant Government Authority as prescribed under Applicable Laws. The consent manager is accountable to you and can assist you in providing or withdrawing your consent to us to process your Personal Data on your behalf. Such consent managers must comply with the obligations imposed on them as may be prescribed under Applicable Laws.
8.5
Changes to the Privacy Policy: We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time, by notifying you of such changes. Any changes or updates will be effective immediately. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the "Last Updated" legend above.
9.
Data Retention and Deletion
9.1
We shall be entitled to retain your Personal Data for such duration as may be required for the purposes specified hereunder or for such other periods as may be required under Applicable Laws, and the said information will be used by us in accordance with this Privacy Policy.
9.2
We will comply with the following procedure for destruction and disposal of your Personal Data:
(1)
IT department is responsible for deleting or destroying electronic records. This includes ensuring that the Personal Data is permanently removed and from company system and destroyed.
(2)
No Personal Data that are currently involved in, or have open investigations, audits, or litigation pending shall be destroyed or otherwise discarded.
(3)
When retention requirements have been met, Personal Data shall be immediately destroyed
(4)
The authorized methods of destruction for non-electronic Personal Data are shredding.
9.3
We may, however, continue to retain your Personal Data in anonymized form for analytical and research purposes.
10.
Grievance Officer
10.1
If you have any grievance with respect to the Platform or the services provided through the Platform, you may write to the grievance officer, the name and contact details have been provided below:
Nipun Doshi, Lead – Compliance
nipun.doshi@ionic.in
10.2
We will resolve your concern in an efficient and timely manner, and in a manner compliant with Applicable Laws in India.
10.3
In the event you have exhausted your opportunity of redressing your grievances with respect to your Personal Information through the grievance officer, you may raise your concern to the relevant Government Authority prescribed under Applicable Laws in India.
11.
Questions
Please feel free to contact us at compliance@ionic.in regarding any questions on the Privacy Policy.