1. We may collect the following personal and sensitive information from you when you visit our digital assets or communicate with us by any mode:
   1. Name.
   2. Date of birth.
   3. Contact information such as address, email, and mobile phone number.
   4. PAN Card.
   5. Payment Details like Credit Card/ Debit Card details along with their expiry date (billing address in case of international debit/credit card).
   6. Lifestyle and social circumstances (for example, your hobbies)
   7. Family details/information (for example, your marital status and dependents).
   8. Employment and education details (for example, the organization you work for, your job title and your education details).
   9. Financial and tax-related information (like your income, investments and tax residency).
   10. Postings or messages on any blogs, forums, platforms, wikis or social media applications of BeWealthy and BeWealthy’s third parties.
   11. IP address, browser type and language, your access times.
   12. Information in any complaints you make.
   13. CCTV footage and other information which we may collect when you visit/access our premises.
   14. Recording of telephone calls to our representatives and call centers.
   15. Details of how you like to interact with us (through email, SMS or whatsapp) and other similar information relevant to our relationship.
   16. Details shared by you over our chatbot , if any.


2. The personal data we collect may also include 'sensitive' personal data such as details about your:
   1. Medical history which you may disclose (or may have disclosed) for insurance purpose.
   2. Sexual orientation (if you provide us with details of your spouse or partner).
   
   If you choose not to provide, or object to us processing the information we collect, we may not be able to process your instructions or continue to provide some or all of our services to you.
   
   If you provide personal information to us regarding individuals other than yourself, you agree
   
   • To inform the individual about the content of this privacy policy.
   • To obtain any legally-required consent, for the collection, use, disclosure, and transfer of individual’s personal information, from the individual in accordance with the legal and regulatory requirements.


3. Personal information of child – The Services are not intended for users under the age of 18 (“Child”), unless permitted under applicable local laws. We do not knowingly collect any personal information from you or from the market to solicit information from any Child. If we become aware that a person submitting personal information is a Child, we will delete the account and any related information immediately. If you believe we might have any information from a Child, please contact us at grievance@bewealthy.co.in. However, a parent or legal guardian of a Child may voluntarily provide personal information about the Child for availing our services in connection with the Child.


4. We use third party services/bots to capture the following additional information:
   1. Analytics
   2. Infrastructure monitoring, Geographic position, unique device identifiers for advertising
   3. Location-based interactions: Geographical locations
   4. Unique device identification: This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

1. Directly: We obtain personal data directly from individuals in a variety of ways, including but not limited to obtaining personal data from individuals who provide their personal information directly on our digital assets, or when they register for webinars and/or attend meetings or events we host or when they visit our offices. We may also obtain personal data directly when we are establishing a business relationship, performing professional service through a contract, or through our hosted software applications.


2. Indirectly: We obtain personal data indirectly about individuals from a variety of sources, which includes but is not limited to your insurance policies which we access after obtaining your consent. We may add personal data to our customer relationship management records to better understand and serve you, or to satisfy a legal obligation.


3. Public sources – Personal data may be obtained from public sources such as news articles and Internet searches.


4. Social and professional networking sites – If you register or login to our websites using social media (e.g., LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you. You are advised to read and review the privacy controls on the applicable service to set how much information you want to share with us.


5. Business clients – Our business clients may engage us to provide products/services offered by us which involves sharing personal data they control as part of that engagement. Our services may also include processing personal data under our client’s control on our digital assets.

We may rely on your Personal Data for the following lawfol reasons when we process the same to operate our business and provide our products and/or services:

1. Contract – We may rely on and process personal information in order to perform our contractual obligations to which you (data subject) or our client (data controller) is party.


2. Consent – We may rely on your consent given by you while accessing our website or mobile application from time-to-time for one or more specific purposes.


3. Legitimate interests – We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced.


4. Legal obligations – We may process personal information where processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data, particularly where the data subject is a child.

1. The information collected from you may be put to any or all of the following use:
   1. For the purpose of distribution of different financial products offered by entities with whom we have a contractual relationship and also in connection with servicing of such financial products.
   2. Information like Credit Card/ Debit Card, Expiry Date and Net Banking Details may be stored and used for processing payments on our Website/Mobile App. We store such information in adherence to the PCI norms and in an encrypted form in a segmented zone. We do not store CVV details. These details may also be processed with the help of certain third parties where certain processes forming part of our services are outsourced to, or dependent on, other service providers.


2. Information like Mobile number, e-mail address and postal address may be used for promotional purposes, unless the customer/user opts-out of such use. These information may also be used for the following purposes: –
   1. To manage and respond to any request you submit through our website.
   2. To meet legal and regulatory requirements.
   3. Promoting our professional services, products and capabilities to existing and prospective business clients/customers.
   4. Sending invitations and providing access to customers attending our events and webinars or our sponsored events.
   5. Personalizing online landing pages and communications we think would be of interest based on interactions with us.
   6. To effectively communicate with you like through SMS, emails or whatsapp.


3. If you choose not to share this information, you can still visit our website, but you may be unable to avail certain options or our services.


4. We use Cookies in following manner – In general, you can visit our website without telling us who you are or revealing any personal information about yourself. We track the Internet address of the domains from which people visit us and analyze this data for trends and statistics, but the individual user remains anonymous.


5. Some of our web pages use “cookies” so that we can better serve you with customized information when you return to our website. Cookies are identifiers which websites send to the browser on your computer to facilitate your next visit to our website. You can set your browser to notify you when you are sent a cookie, giving you the option to decide whether or not to accept it. The information we collect and analyse is used to improve our service to you.

   To learn more about the use of cookies, please refer Annexure A: Cookie policy.



6. Permissions required to use various features in our BeWealthy app: – In order to have a better experience and to use all features in the app, we need below permissions to be used in our app:
   1. Camera: We will not access your photos or camera without first getting your permission. We will only use images that you specifically choose to share with us.
   2. Contacts: We will not scan or import your contacts stored on your phone without first getting your explicit permission. We will only use the contact information to help you find friends or contacts who use BeWealthy Applications, if you choose to do so, and we will not use contact information for any other purpose without first getting your permission.
   3. Calendar: This permission enables us to mark such dates on your calendar which are important for you in connection with the services availed by you on our platform.
   4. Location: We will not gather or use the specific location of your mobile device (by using, for example, GPS or Bluetooth) without first getting your explicit permission. And if you choose to share location information but later change your mind, you will always have the option to stop sharing. Please note that this does not include IP address. This permissions will enable us to provide you a personalized location specific experience, as may be applicable to you.
   5. Storage: We use this permission to enable you to upload picture or video from device storage and also to download files to the device storage.
   6. Microphone: This permission is used to enable you to record and upload video.
   7. Notification: We need this permission to send push notifications to the users.
   8. Get Accounts: This permission enables us to know about details of your account(s) on your mobile device. This will help you to get registered on the Platform by logging into online accounts you may have with Third Party social networking sites (e.g. Facebook, Google Login etc.)
   9. Access WiFi State: By using Wi-Fi connection details, we provide you a seamless experience depending upon your network. We try to use this information to optimize the app’s performance on slow networks.
   10. Third Party: The User allows us to provide services to third party service accounts for Displaying content from external platforms, SPAM protection, Hosting and back-end infrastructure, Infrastructure monitoring, Content commenting, Interaction with external social networks and platforms, Location-based interactions, Social features, Contacting the User, User database management, Targeted Advertising and Re-marketing and behavioral targeting.


7. In addition to these permissions, permission for SMS/ Whatsapp is additionally required by our Android Application. BeWealthy application reads, uploads and do syntactic analysis of text messages initiated through the application. This information is stored in a secured environment and always transmitted using SSL.

In connection with any of the purposes outlined in this Privacy Policy, we may disclose details about you to:

1. Insurance Companies or other such finance companies with whom we may have business tie-up for distribution of their financial products;


2. suppliers of IT based solutions and products that assist us in providing services to you (such as any external data hosting and monitoring providers we may use, communication service providers);


3. Competent authorities (including auditors, courts and authorities regulating us for internal compliance and audit(s)) as required or authorized by applicable law, and to comply with our legal and regulatory obligations;


4. Credit reference agencies or other third party organizations who may help us conduct risk checks to reduce the incidence of fraud;e. Other organizations to whom we may transfer our rights and/or obligations under the Terms agreed between BeWealthy and such other organization;


5. Any other person or organization after a restructure, sale or acquisition of any member of the BeWealthy group, as long as they use your personal information for the same purposes we did;


6. The analytics service providers with whom we may share IP addresses, browser type, operating system, referring URLs, and other technical information;


7. We share following data with our service providers to send any personalized App Notification to the end user of our applications
   1. Name
   2. Email Address
   3. Mobile Number
   4. User ID
   5. User’s Location;


8. We may also share your personal information with such third parties who may reasonably require access to personal data relating to you for providing services to you. With specific reference to third party, we may use third-party service providers to serve ads on our behalf across the Internet and/or on our digital assets. They may collect anonymous information about your visits to our website/mobile app. They may also use information about your visits to our digital assets or other websites/mobile apps to target advertisements for goods and services. This anonymous information may be collected through industry standard technology used by various major websites. No personally identifiable information is collected or used in this process. Such third parties do not know your name, phone number, address, email address, or any personal information which can identify you.


9. Our website/mobile application may host various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you contribute to these Social Media Applications shall not get covered by this privacy policy.

As on the date of release of this Privacy Policy, we do not transfer your personal information outside India. But, in future, your personal Information we hold may be transferred to countries:

1. where we commence business


2. which are linked to your engagement with us


3. from which you regularly receive or transmit information


4. Where our third parties conduct their activities



We may share non-personal, anonymized and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.

We have implemented appropriate technical and organizational measures to safeguard and help prevent unauthorized access to your information and to maintain data security. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access or other causes beyond our control. You play an important role in keeping your personal information secure. You should not share your user name, password, or other security information with anyone else either on our digital assets or anywhere else. If we receive instructions using your registered email ID or username, we will consider that you have authorized the instructions.

Your data protection rights are highlighted below:

1. Right to Access – You may ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.


2. Right to Correction – You may ask us to correct our records if you believe they contain incorrect or incomplete information about you.


3. Right to Erasure – You may ask us to erase (delete) your personal data after you withdraw your consent to process it, or when we no longer need it for the purpose it was originally collected and we shall erase your personal data, subject to the data retention requirements under the applicable rules, regulations, guidelines, law, by-law, to meet our legal/regulatory obligations. Please note, even after completion of your request regarding account or data deletion, we will be retaining transactional data to meet our legal obligations.


4. Right to Processing restrictions – You may ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.


5. Right to Withdraw Consent – You may withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. However, this may lead to BeWealthy not able to provide certain products or services to you.



We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

We seek to ensure that we only keep your personal data for the longest of: –

1. the period necessary for the relevant activity or services


2. any retention period that is required by law


3. the period in which litigation or investigations might arise in respect of the services, and if any litigation or investigation has actually arisen, then till expiry of statutory data retention period post completion/final closure of such litigation/investigation.



Even after your account is terminated, we retain your transactional data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.

From time to time we may update this Privacy Policy. When we do, we will publish the changes on our Website/Mobile App. If you do not agree with these changes, you can discontinue your use of our Website/Mobile App.

If you have a question, comment, grievance or complaint or wish to access a copy of your personal data or to correct it if you believe it is inaccurate, you may contact us at grievance@bewealthy.co.in.