PRIVACY POLICY

  1. Introduction

    This privacy policy governs your use of ETF Junction services provided via our software, APIs, or otherwise and mobile website and mobile applications related, linked, or otherwise connected thereto (the “Platform”) operated by Financial Basket Capital Pvt Ltd, a duly registered company in India with registered business address at B-7, 3rd Floor, Jungpura Ext, New Delhi, Delhi India 110014, bearing CIN [ENTER CIN] (“ETF Junction”, “we”, “our”, “us”). Our privacy policy may change from time to time for any reason. If we make any material changes to our policies, we will place a prominent notice on our Platform. If you have any questions or concerns about our privacy policies, feel free to mail us at TermsANDprivacy@etfjunction.com

    Data protection is a particularly high priority for the management of ETF Junction. The use of the Platform is not possible without any indication of personal data, if a data subject wants to use our Platform, processing of personal data is necessary.

    The processing of personal data, such as the name, address, e-mail address, or phone number of a data subject shall always be in line with the Information Technology Act, 2000 and other regulations applicable to ETF Junction. Utilizing this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed through this data protection declaration, of the rights to which they are entitled.

    As the controller, ETF Junction has implemented numerous technical and organisational measures to ensure the complete protection of personal data processed through the Platform. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.

  2. Definitions

    The data protection declaration of ETF Junction is based on the terms used for the adoption of the Information Technology Act, 2000, and other regulations applicable to ETF Junction. Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, among other things, the following terms:

    A. Personal data: Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

    B. Data subject: Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

    C. Processing: Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

    D. Restriction of processing: Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

    E. Profiling: Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

    F. Pseudonymisation: Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

    G. Controller or controller responsible for the processing: Controller or controller responsible for the processing is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by the controller or the specific criteria for its nomination may be provided for by law.

    H. Processor: Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

    I. Recipient: Recipient is a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

    J. Third party: Third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

    K. Consent: Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

  3. Name and Address of the controller

    Controller related to data is [ENTER COMPANY NAME], a duly registered company in India with registered business address at [ENTER ADDRESS], bearing CIN [ENTER CIN].

  4. COLLECTION OF GENERAL DATA AND INFORMATION

    The Platform of ETF Junction collects a series of general data and information when a data subject or automated system calls up the Platform. This general data and information are stored in the server log files. The general data collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our Platform (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Platform, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, (8) names, (9) email address, (10) Payment method details such as credit card details (11) phone numbers and, (12) users access of content on ETF junction, click streams, and other activity on the platform (13) any other similar data and information that may be used in the event of attacks on our information technology systems.

    All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

    When using these general data and information, ETF Junction does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our Platform correctly, (2) show investment strategies and investment options. (3) optimize the content of our Platform as well as its advertisement, (4) ensure the long-term viability of our information technology systems and website technology, (5) for analytics purposes (such as click and preference analytics), (6) to facilitate account creation and logon process, (7) request feedback (8) as necessary for basic functionality of the Platform and account management (billing our clients) and, (9) to serve content applicable to the user (10) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, ETF Junction analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise and to achieve an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

  5. Mobile Push Notifications/Alerts

    With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

  6. Security

    This Platform ensures that data is encrypted when leaving the Platform. This process involves the converting of information or data into a code to prevent unauthorised access. This Platform follows this process and employs secure methods to ensure the protection of all credit and debit card transactions. Encryption methods such as SSL are utilised to protect customer data when in transit to and from this Platform over a secure communications channel.

    Whilst we do everything within our power to ensure that personal data is protected at all times from our Platform, we cannot guarantee the security and integrity of the information that has been transmitted to our Platform.

  7. DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF GOOGLE ANALYTICS (WITH ANONYMIZATION FUNCTION)

    On this Platform, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

    The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

    For the web analytics through Google Analytics, the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our Platform from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

    The purpose of the Google Analytics component is to analyses the traffic on our Platform. Google uses the collected data and information, among other things, to evaluate the use of our Platform and to provide online reports, which show the activities on our Platform, and to provide other services concerning the use of our Platform for us.

    Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyses the use of our Platform. With each call-up to one of the individual pages of this Platform, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

    The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our Platform by the data subject. With each visit to our Platform, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

    The data subject may, as stated above, prevent the setting of cookies through our Platform at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

    In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this Platform, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript that any data and information about the visits of Platform may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

    Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

  8. DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF Social features

    On this Platform, the controller has integrated social components enabling networking with other users similar to Facebook. A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a website for the exchange of opinions and experiences or enable the Internet community to provide personal or business-related information. These features allow our users to include the creation of private profiles, upload photos, and network through friend requests.

  9. DATA PROTECTION PROVISIONS

    We collect some user data which is shared by the users themselves. We track user behaviour to improve our marketing efforts, for statistical and market research purposes. The data collected in this way is anonymous to us, i.e., we do not see the personal data of individual users. However, this data is stored and processed by us, which is why we are informing you, based on our knowledge of the situation. We might allow our partners to place ads on and off your newsfeed. A cookie may also be stored on your computer for these purposes. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. If you object to the collection of your data, please immediatey stop using this platform.

  10. PAYMENT METHOD: DATA PROTECTION PROVISIONS ABOUT THE USE OF PAYPAL AND STRIPE AS A PAYMENT PROCESSOR

    On this Platform, the controller has integrated components of PayPal and Stripe. PayPal and Stripe are online payment service providers. Payments are processed via so-called PayPal and Stripe accounts, which represent virtual private or business accounts. PayPal and Stripe are also able to process virtual payments through credit cards when a user does not have a PayPal or Stripe account. A PayPal or Stripe account is managed via an e-mail address, which is why there are no classic account numbers. PayPal and Stripe make it possible to trigger online payments to third parties or to receive payments. PayPal and Stripe also accept trustee functions and offers buyer protection services.

    The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg. Stripe’s services in Europe are provided by a Stripe affiliate—Stripe Payments Europe Limited (“Stripe Payments Europe”)—an entity located in Ireland. In providing Stripe Services, Stripe Payments Europe transfers personal data to Stripe, Inc.

    If the data subject chooses “PayPal” or “Stripe” as the payment option in the online shop during the ordering process, we automatically transmit the data of the data subject to PayPal or Stripe accordingly. By selecting these payment options, the data subject agrees to the transfer of personal data required for payment processing.

    The personal data transmitted to PayPal or Stripe is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires such personal data, which are in connection with the respective order.

    The transmission of the data is aimed at payment processing and fraud prevention. The controller will transfer personal data to PayPal or Stripe, in particular, if a legitimate interest in the transmission is given. The personal data exchanged between PayPal or Stripe and the controller for the processing of the data will be transmitted by PayPal or Stripe to economic credit agencies. This transmission is intended for identity and creditworthiness checks.

    PayPal or Stripe will, if necessary, pass on personal data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfil contractual obligations or for data to be processed in the order. The data subject has the possibility to revoke consent for the handling of personal data at any time from PayPal or Stripe. A revocation shall not have any effect on personal data which must be processed, used, or transmitted in accordance with (contractual) payment processing. The applicable data protection provisions of PayPal and Stripe may be retrieved under https://www.paypal.com/us/webapps/mpp/ua/privacy-full. And https://stripe.com/en-in/privacy respectively.

  11. DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF MAILCHIMP

    On this Platform, the controller has integrated MailChimp or might decide to use another service. MailChimp is an online service provider which allows advertising for growth of business. The purpose of MailChimp’s integration is to promote the services of the Platform to existing users as well as to potential new users. MailChimp’s data privacy policy is further explained under the following link. Privacy Policy
    Data Processing Addendum

  12. Security

    The security of your personal data is very important to us. When we collect your personal data online, we use reasonable efforts to protect it from unauthorized access. However, due to the inherent open nature of the Internet, we cannot guarantee that your personal data will be completely free from unauthorized access by third parties such as hackers, and your use of our Platform demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personal data.

    ETF Junction shall investigate and report data breaches within 72 hours of becoming aware of such breach. When a breach of personal data is likely to result in a high risk to the rights and freedoms of individuals then ETF Junction, as Controller, will notify the affected individuals without undue delay.

  13. Protection for Children

    The use of ETF Junction is intended for and directed to adults. Our Platform is not directed to minors, and we do not knowingly collect personal information from minors. When we become aware that personal data from a child under 18 has been collected without such child's parent or guardian's consent, we will use all reasonable efforts to delete such information from our database.

  14. Changes to this Privacy Policy

    We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. However, if at any time in the future we plan to use personal data in a way that materially differs from this Privacy Policy, including sharing such information with more third parties, we will post such changes here and provide you the opportunity to opt-out of such differing uses. Your continued use of the Platform and our services following the posting of any changes to this Privacy Policy means you accept such changes.

  15. Opt-Out Process

    All unsubscribe or opt-out requests may be made by changing your Platform settings or by clicking the "unsubscribe" link at the bottom of the relevant email. We will process your request within a reasonable time after receipt. However, we are not responsible for, and in some cases, we are incapable of, removing your personal data from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy or your consent. You should contact such third parties directly.

  16. Communications with ETF Junction

    By providing your contact information through channels including but not limited to your email address, phone number (collectively the "Channels") to us, you expressly consent to receive communications from us. We may use the Channels to communicate with you, to send information that you have requested or to send information about other products or services developed or provided by us or our business partners, provided that, we will not give your contact information to another party to promote their products or services directly to you without your consent or as set forth in this Privacy Policy.

    By providing your phone number to us, you expressly consent to receive phone calls and/or text messages from us. We will not give your phone number to another party to promote their products or services directly to you without your consent or as set forth in this Privacy Policy.

    Any phone calls and/or text messages delivered to your phone or device may cause you to incur extra data, text messaging, or other charges from your phone provider. MESSAGE AND DATA RATES MAY APPLY. You are solely responsible for any carrier charges incurred as a result of phone and/or text communications from ETF Junction.

    Any communication or material you transmit to us by email or otherwise, including any data, questions, comments, suggestions, or the like is, and will be treated as, non-confidential and nonproprietary. Except to the extent expressly covered by this Privacy Policy, anything you transmit, or post may be used by us for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting. Furthermore, you expressly agree that we are free to use any ideas, concepts, know-how, or techniques contained in any communication you send to us, as well as any data developed using the content of such communication, without compensation and for any purpose whatsoever, including but not limited to, developing, manufacturing, and marketing products and services using such information.

  17. No Rights of Third Parties

    As a convenience to you, we may provide links to third-party websites from within our Platform. We are not responsible for the privacy practices or content of these third-party sites. When you link away from our Service, you do so at your own risk. This Privacy Policy does not create rights enforceable by third parties, nor does it require disclosure of any personal information relating to users of the Service.

  18. Contact

    Please contact us with any questions or comments about this Privacy Policy, transfer of your personal information, our privacy practices, or your consent choices by email at Termsandprivacy@etfjunction.com.