FINAQA SOLUTIONS PRIVATE LIMITED (“FinaQA” or “the Company”) owns, operates and maintains the mobile application “FinaQA” (“Application”) and / or the “FinaQA” web page (“Web Page” along with Application referred to as “Mobile App”).

This privacy policy (“Privacy Policy”) explains how we collect, use, share, disclose and protect personal information of the users of the Mobile App. The Company respects the privacy of its Mobile App users and is committed to protecting their privacy. The Company has accordingly created this statement to outline its information gathering and dissemination practices.

By using / visiting the Mobile App, you will automatically be taken to have read the Privacy Policy and you agree to be bound by the Privacy Policy which should be read with the Terms of Use that are laid down by the Company. If you do not agree, please do not download, access or use the Mobile App. Even by merely downloading or cursorily accessing this Mobile App, you expressly consent to the Company’s use and disclosure of your personal information in accordance with this Privacy Policy. We will keep your information only for so long as is required for the purpose for which it is collected or as is required under the law.

If you use the Mobile App on behalf of a Consultant, you represent that you are authorised by the said Consultant

1. To accept this privacy policy on such Consultant’s behalf
2. To consent on behalf of such Consultant to our collection, use and disclosure of such Consultant’s information as described in this Privacy Policy.

All capitalized terms not defined in this Privacy Policy will have the same meaning as ascribed in the Terms of Use.

• Why this Privacy Policy?
• This Privacy Policy is published in compliance with, inter alia, the applicable law i.e. the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”), and Information Technology (Intermediaries Guidelines) Rules, 2011.

• What we mean by personal information?
• The personal information collected from you through FinaQA may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPI Rules. “Personal Information” is defined under the SPI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person. The SPI Rules further define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:
  1. Passwords
  2. Financial information such as bank accounts, credit and debit card details or other payment instrument details
  3. Sexual orientation
  4. Biometric information
  5. Information received by body corporate under lawful contract or otherwise;
  6. Visitor details as provided at the time of registration or thereafter; and call data records.
• For the ease of reference, the “Personal Information” and the “Sensitive Personal Data or Information” will be jointly referred to as “Personal Information”. The Personal Information may also include any information pertaining to a user’s license/qualification/registration to practice as a consultant and its registration thereof with the required authority.
• Collection, use and disclosure of information which has been designated as Personal Information or Sensitive Personal Data or Information’ under the SPI Rules requires your express consent. By affirming your assent to this Privacy Policy, you provide your consent to such use, collection and disclosure as required under applicable law.
• All Personal Information that we obtain from you in relation to the Mobile App will be dealt with in accordance with the provisions of this Privacy Policy.

• Collection of Personal Information
• The information voluntarily chosen by you to be publicly displayed becomes published content and will be available on our Mobile App. Such information will be exempted from the purview of being considered as Personal Information. The Company collects your Personal Information (including full name, date of birth, gender, PAN, Aadhaar, registration certificate, bank account details, address, contact details, e-mail address, IP address and standard web log information and degree certificate) while setting up an account with “FinaQA”. The Company may use your Personal Information to contact you from time to time, in order to ask for your views on the application and to notify you occasionally about important changes or developments to the Mobile App. Further, the Company may directly or indirectly also collect and store your information like sign-on data, statistical information on page views, tracking usage pattern, information pertaining to access time, traffic to and from “FinaQA” and advertisement data. The said collection of information would be collected through cookies – although you may take requisite steps to disable the cookies as we believe that this may affect your ability to use the Mobile App in order to make your visits to the Mobile App more useful and rewarding. The Company may also obtain Personal Information when the user uses in- app mechanisms. The aforesaid information so collected and stored by the Company may also be used, if necessary, to deny services in accordance with our Terms of Use. The Company stores and processes the Personal Information received by its users on computers that are protected by physical as well as technological security devices. The Company also uses third parties to verify and certify the Company’s privacy principles. If you object to your Personal Information being transferred or used in this way please do not access, use or download the Mobile App.

• Use of the Personal Information
• The Company may use your Personal Information to send texts/ e-mails for administrative purposes as well as provide their services including scheduling a Consult and / or a Session, if need be. The Company likewise collects and stores information to resolve disputes, troubleshoot problems, and enforce our policies. Similarly, the Company uses the information provided by you to customize the users' experience, measure interest in their services, inform users about services and updates, and communicate marketing and promotional offers to you.

• Disclosure of the Personal Information
• All information collected and stored by FinaQA is treated as strictly confidential and the Company shall take all necessary precautions to ensure that such confidential and personal information is not shared with or disclosed to any third parties except in the following cases:
  1. Disclosure required from time to time by Governmental or law enforcing agencies or our regulators, but it will be done so only under proper authority.
  2. The right to make use of the Personal Information in any investigation or judicial process relating to fraud on account of commercial transactions, if any, during the period the Company retains such information.
  3. To enforce the Company’s policies or to respond to claims that a posting on the Mobile App or any other content on the Mobile App either violates a third party’s rights, or protects a third party’s rights, property or safety.
  4. The Company may also share your Personal Information with its corporate affiliates or its service partners who may help detect or prevent potentially illegal acts and provide such joint services.
  5. If the Company or its corporate affiliates are involved in a merger or acquisition, the Company may share the Personal Information with another company, but this Privacy Policy will continue to be binding on the users till such time that policy comes in effect.
  6. The Company likewise may share the Personal Information with its third-party developers in order to improve user experience and add new features after obtaining appropriate undertaking from said third party developers for the safe keeping of the Personal Information.
  7. The Company would also like to bring to your notice that you will be required to submit your Personal Information, specifically financial details, at the time of making any form of commercial transaction from FinaQA. The Company will be using an online payment gateway that is operated by a third party and the Personal Information shared by you in this regard is transferred and shared with such third party being the payment gateway operator. To the best of its knowledge and belief, the Company would also like to assure you that extremely sensitive information like your bank account details are transacted upon secure sites digitally under encryption, thereby providing the highest possible degree of care are available as per current technology. The Company would like to nevertheless advise you that Internet technology is not completely secure and you may exercise your discretion on using the same.

• Using a third party’s personal information from FinaQA
• You may use third party personal information gathered from FinaQA in relation to a Consult and / or a Session only to contact and / or follow up and / or schedule a Consult and / or a Session. The aforesaid information cannot be used to send for spamming / phishing or collecting personal information from someone who has not consented to that. You, and not FinaQA, will be solely liable in law for misuse of the third-party personal information.

• Review, Alteration and Deletion of Personal Information
• You may see and alter or delete your Personal Information by reviewing your posting or account status tab. Further, you may contact the Company’s customer support portal at support@finaqa.com to review any Personal Information that the Company collects and stores in its record but is not available for review on Mobile App. Please be informed that there may be a fee associated with such requests although these will not exceed the amounts permitted by law. In any event, your registration on the Mobile App may be terminated at FinaQA’ discretion, in case you alter your Personal Information without proper procedure. Moreover, You agree that FinaQA retains your Personal Information for future audit purposes even after you have uninstalled the app and are not using the website for consultations through FinaQA.

• Data Security of the Personal Information
• The Company would like to inform you that they use a number of mechanisms (encryption, passwords, physical security, etc.) to protect the security and integrity of your Personal Information against unauthorized access and disclosure. The Company would also like to assure you that they will use the Personal Information received from you only in accordance with the Privacy Policy under which the information was collected unless they have received explicit authorization from you to do so otherwise. In view of the fact that no data transmission over the internet can be guaranteed to be completely secure, so while the Company takes adequate measures to protect such information, they cannot ensure or warrant the security of any Personal Information you transmit to the Company and that you do so at your own risk. Nevertheless, once any Personal Information comes into our possession, the Company will take reasonable steps to protect that information from misuse and loss and from unauthorized access, modification or disclosure.

• Confidentiality of Personal Information
• You agree and accept that you have been fully informed by the Company that the use of any specific feature may lead to publication, to all users of FinaQA, of any Personal Information posted by them. You further agree and accept that the terms of the Privacy Policy will be applicable to the use of all features, existing and upcoming. However, you agree and accept that confidentiality of information posted on such features has been waived by you of such features themselves.

• Disclaimer
• The Company’s Privacy Policy may be updated, upgraded, modified (partially and/or completely) without prior notice. It is accordingly recommended that you check it periodically to ensure that you are aware of the same.