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Privacy
Policy

1. Introduction

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This Privacy Policy details the types of personal information we collect, how it is gathered, and our efforts to protect it. Our commitment to your privacy is paramount, and we take the responsibility of handling your personal information seriously. By interacting with us, you agree to the collection and use of information in accordance with this policy.

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2. Information Collection

2.1 Types of Information Collected

We may collect the following information:

  • Name and Contact Details: We may collect personal information directly from you, such as your name, email address, contact details, or other identifiers, when you register an account, make a purchase, or interact with certain features of the application. Your personal information is used to provide you with access to the application's features and functionalities, personalize your experience, and communicate with you about your account or transactions.

  • Collection/Use of Image Data: When you grant permission, our application may access your device's camera or photo gallery to enable features that involve capturing, uploading. The images you upload or capture within our application may be used for document verification in Video KYC by the application. We do not share your image data with third parties unless required by law or necessary to provide the services you have requested.

  • Use of Location Data: We access your location to verify your identity and grant access to the application's features and functionalities.

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3. Methods of Collection

3.1 Direct Interactions

We collect information from you when you engage with us directly. This could occur when you:

  • Contact us about our activities

  • Register as a supporter

  • Send or receive information

  • Sign a petition

In these instances, you knowingly provide us with your personal details.

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3.2 Third Parties

We may also receive information about you from third parties, provided you have given them permission to share your information with us.

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4. Confidentiality and Security

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Your personal information is protected from unauthorized access, alteration, disclosure, or destruction through industry-standard security measures. You have the right to control and manage your personal information within the application. You can update your account details, manage your communication preferences, or exercise your rights under applicable data protection laws. You can also choose to delete your account or request the deletion of certain personal information by contacting us through the provided channels or using the option available in the app settings page. Despite our efforts, we must caution that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Please note, we are not liable for any data theft or data leaks resulting from unauthorized access to our databases.

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5. Complaints and Queries

5.1 Making a Complaint

If you have any concerns or complaints about how your personal information is handled, please contact us at helpdesk@pivotalflow.com with a detailed explanation of your concerns. We are committed to reviewing every complaint, investigating whether appropriate procedures were followed, and responding accordingly.

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5.2 Response Time

We aim to complete our investigation and respond to your complaint within 15 working days of receipt. Please understand that, in certain cases, the investigation may require more time.

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5.3 Further Assistance

If, after receiving our response, you are still not satisfied with the outcome, please do not hesitate to contact us again for further assistance.

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6. Updates to This Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our website. You are advised to review this Privacy Policy periodically for any changes. This Privacy Policy outlines our practices regarding the collection, use, and protection of your information. By using our application, you agree to the terms outlined in this policy. If you have any questions or concerns about our privacy practices, please contact us through the provided channels.

 

7. Contact Us

For more information about our privacy practices, or if you have questions, please contact us by email at helpdesk@pivotalflow.com.

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GENERAL INFORMATION

Nikhil Suresh Khatiwala (ARN-54387), operating under the brand PivotalFlow Financial, is committed to protecting the personal data of investors and website visitors. This Privacy Policy explains what data we collect, why we collect it, how it is kept and shared, and the rights you have under the Digital Personal Data Protection Act, 2023 (DPDPA).

We collect only the data needed for Mutual Fund distribution and regulatory compliance: name, address, date of birth, PAN, Aadhaar for KYC where applicable, contact details, bank details, nomination details, FATCA/CRS self-certification, risk profile responses, income range and investment goals, and transaction history. Our website may also collect technical data such as IP address, browser and device type through cookies.

Your data is used to complete KYC, assess your risk profile, process your transactions, send you confirmations and statements, respond to your queries and complaints, and meet reporting obligations to SEBI, AMFI and other authorities. We do not use your data for any other purpose.

We share your data only with AMCs and their Registrars for processing transactions; with KYC Registration Agencies and the Central KYC Registry for KYC; with the transaction platform through which orders are placed; with SEBI, AMFI and their appointed auditors on request; and with our software provider for record keeping under a confidentiality agreement. We do not sell, rent or share your data with any third party for marketing.

Digital records are kept in password-protected systems with restricted access. Physical documents are kept in locked storage at our office. Records are retained for the period required under the Prevention of Money Laundering Act, 2002, SEBI and AMFI rules and the Income Tax Act, 1961, and are then securely destroyed.

Under the DPDPA you may ask us to show you the personal data we hold about you, correct it, or erase it where the law allows. You may withdraw consent to processing at any time, subject to our regulatory retention obligations; withdrawal may affect our ability to continue serving you. You may also complain to the Data Protection Board of India. To exercise any of these rights, write to the Grievance Contact given below.

Our website uses cookies to remember your preferences and measure traffic. You can disable cookies in your browser; some features may then not work. Links to external websites, including AMC, SEBI and AMFI websites, are provided for convenience and we are not responsible for their content or privacy practices.

This policy may be updated when our practices or the law change. The current version is always the one published on this page.

Grievance Contact for privacy matters: Nikhil Suresh Khatiwala, invest@pivotalflow.com, +91-98222 06851, S-11, 2nd Floor, Destination Centre-1, Nanded City, Sinhgad Road, Pune – 411041.

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