This policy describes how sainik suvidha collects, stores, uses and otherwise processes your Personal Information through sainiksuvidha.in websites, Sainik Suvidha Applications, m-sites, chatbots, notifications or any other medium used by Sainik Suvidha to provide its services to you (hereinafter referred to as the “Platform”). By visiting, downloading, using Sainik Suvidha Platform, and/or, providing your information or availing our product/services, you expressly agree to be bound by this Privacy Policy (“Policy”) and the applicable service/product terms and conditions. We value the trust you place in us and respect your privacy, maintaining the highest standards for secure transactions and protection of your personal information.

At Sainik Suvidha, we highly regard Data Protection Laws and have constructed our privacy policies, according the stated regulations. This page states and confirms our uses limitations and liability towards information used through this site. We strictly recommend that you must go through each word of this page before starting any process with us or subscribing to any of our services. To be our user and subscribe all our offered services, you must agree with our policies stated here.

This Privacy Policy is published and shall be construed in accordance with the provisions of Indian laws and regulations including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under the Information Technology Act, 2000, the Aadhaar Act, 2016 and its Amendments, including the Aadhaar Regulations; that require publishing of the privacy policy for collection, use, storage, transfer, disclosure of Personal Information. Personal Information means and includes all information that can be linked to a specific individual and also includes Sensitive Personal Information (all Personal Information which requires heightened data protection measures due to its sensitive and personal nature), both, hereinafter referred to as “Personal Information”, excluding any information that is freely available or accessible in public domain. Please note, Our products/services are offered in India for Indian customers, and your Personal Information processing will be subject to Indian laws. If you do not agree with this Privacy Policy, please do not use or access our Platform.

Personal information collected by us

We may collect your Personal Information when you use our services or Platform or otherwise interact with us during the course of our relationship. We collect Personal Information which is relevant and absolutely necessary for providing the services requested by you and to continually improve the Sainik Suvidha Platform.

Personal and Sensitive Personal Information collected, as applicable, includes, but are not limited to:

• Goverment Services related information such as PAN, income details, your business-related information, videos or other online/ offline verification documents as mandated by relevant regulatory authorities.
• Aadhaar information including Aadhaar number or Virtual ID for the purposes of e-KYC authentication with the Unique Identification Authority of India (UIDAI). Note that submission of Aadhaar information is not mandatory and there are alternatives to submission of identity information (e.g., Voter ID, DL)
• OTP sent to you by your service provider, NSDL or Sainik Suvidha
• We collect personal data such as name, age, gender, photo, address, phone number, e-mail id, your contacts, nominee details.
• This information is collected when you register with us or subscribe our services.
• Other personal information that you will enter during any process will not be accessed by us at any circumstances without taking authorized permission from you.
• If you are sharing any personal information of your spouse or family members with us, then we will assume that you have taken permission from them.
• your Short Messaging Service (SMS(es)) that are stored on your device for the purposes of, including but not limited to, registering you and your device for payments or investment services, OTPs for logins and payments, enhancing your security, bill payments and recharge reminders, and any other legitimate uses with your explicit consent.

Purpose and Use of Information

Sainik Suvidha may process your Personal Information for the following purposes:

• creation of your account and verification of your identity and access privileges
• provide you access to the products and services being offered by us, merchants, registered investment advisors, research analysts, entities, subsidiaries, sellers, logistic partners, or business partners
• fulfill your service request
• to meet legal obligations
• to conduct the Goverment services KYC compliance process as a mandatory prerequisite as per the requirements of various regulatory bodies, including UIDAI under the Aadhaar Act and its Regulations
• to inform you about online and offline offers, products, services, and updates; customizing and improving your experience by marketing, presenting advertising, and offering tailored products and offers
• to identify security breaches and attacks; investigating, preventing, and taking action on illegal or suspected fraud or money laundering activities and conducting forensic audits as part of internal or external audit or investigation by Sainik Suvidha or government agencies located within India or outside the Indian jurisdiction
• While we may also process your Personal Information for other legitimate business cases, we ensure to take appropriate steps to minimize the processing to the extent possible, making it less intrusive to your privacy.
• Please note that when providing you with account aggregator services, we do not store, use, process, or have access to any financial information that you choose to transmit under our services.
• The information we collect and store with us will be used only for statistical analysis towards calculating our website performance.
• We also use this data for our own marketing purposes but we never share or forward this information to any other organizations.
• To use the collected information for marketing purposes also, we will take your rightful consent first as we respect your privacy.
• At no circumstances, the collected data will be shared outside our organization without taking your consent.

Information Sharing and Disclosures

Your Personal Information is shared as allowed under applicable laws, after following due diligence and in line with the purposes set out in this Policy.

We may share your Personal Information with different categories of recipients such as business partners, service providers, sellers, logistic partners, merchants, Wealthbasket curators, entities, subsidiaries, legally recognized authorities, regulatory bodies, governmental authorities, financial institutions, internal teams such as marketing, security, investigation team, etc.

Personal Information will be shared, as applicable, on need-to-know basis, for the following purposes, including but not limited to:

• for enabling the provision of the products/services availed by you and facilitating the services between you and the service provider, registered investment advisors, research analysts, sellers, logistic partners, as requested
• for complying with applicable laws as well as meeting the Know Your Customer (KYC) requirements as mandated by various regulatory bodies, whose regulated service/product you opt through our services/Platforms
• for completing a payment transaction initiated by you on a merchant site, where based on your instructions, the merchant requests to fetch your Personal Information from us
• for the purpose of processing your financial product subscription requests placed with us and ensuring that these requests reach the relevant financial institution whose service/product you have opted for
• if it is required by financial institutions to verify, mitigate, or prevent fraud or to manage risk or recover funds in accordance with applicable laws/regulations
• for services related to communication, marketing, data and information storage, transmission, security, analytics, fraud detection, risk assessment and research enforce our Terms or Privacy Policy;
• respond to claims that an advertisement, posting, or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public
• if required to do so by law or in good faith we believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process
• if requested by government authorities for government initiatives and benefits
• for grievance redressal and resolution of disputes
• with the internal investigation department within Sainik Suvidha or agencies appointed by Sainik Suvidha for investigation purposes located within or outside the Indian jurisdiction
• should we (or our assets) plan to merge with, or be acquired by any business entity, or re-organization, amalgamation, restructuring of our business then with such other business entity

While the information is shared with third parties as per purposes set out in this Policy, processing of your Personal Information is governed by their policies. Sainik Suvidha ensures stricter or no less stringent privacy protection obligations are cast on these third-parties, wherever applicable and to the extent possible. However, Sainik Suvidha may share Personal Information with third-parties such as legally recognized authorities, regulatory bodies, governmental authorities, and financial institutions as per purposes set out in this Policy or as per applicable laws. We do not accept any responsibility or liability for usage of your Personal Information by these third parties or their policies.

The Help Center and FAQ pages

• Any comment made by you in our Help Center and FAQ pages will be visible to others whoever will access our website.
• These sections of our website may have additional conditions for using them.
• The comments or discussion made in our pages by other users does not reflect our own views. These are strictly personal views of that particular user.

Storage and Retention

To the extent applicable, we store Personal Information within India and retain it in accordance with applicable laws and for a period no longer than it is required for the purpose for which it was collected. However, we may retain Personal Information related to you if we believe it may be necessary to prevent fraud or future abuse or if required by law such as in the event of the pendency of any legal/regulatory proceeding or receipt of any legal and/or regulatory direction to that effect or for other legitimate purposes.

Once the Personal Information has reached its retention period, it shall be deleted in compliance with applicable laws.

Business Obligations

• We will only transfer any information to a third party if we merge or sell our business to them.
• In such circumstances, the third party will have to agree with our stated policies in here.
• However, for such instances, you will be notified beforehand to make your decision about keeping your data with us or not.
• All our subsidiaries have the right to access the non-personal data such as cookies or IP address for statistical analysis.

Reasonable Security Practices

Sainik Suvidha has deployed administrative, technical, and physical security measures to safeguard user’s Personal Information and Sensitive Personal Information. Specifically, in order to safeguard your Aadhaar information, we have implemented applicable security controls as given under and required by the Aadhaar Regulations. We understand that as effective as our security measures are, no security system is impenetrable. Hence, as part of our reasonable security practices, we undergo strict internal and external reviews to ensure appropriate information security encryption or controls are placed for both data in motion and data at rest within our network and servers respectively. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited.

Further, you are responsible for maintaining the confidentiality and security of your login id and password. Please do not share your Sainik Suvidha login, password, and OTP details with anybody. It shall be your responsibility to intimate us in case of any actual or suspected compromise to your Personal Information.

We have provided multiple levels of security to safeguard the Sainik Suvidha Application by login/logout option and Sainik Suvidha Application lock feature (“Enable Screen Lock”) that can be enabled by you. We have preventive controls implemented to ensure you use Sainik Suvidha Application on your device and the same login credentials cannot be used on different device without any additional authentication/OTP.

Third-Party Products, Services, or Websites

When you are availing products and services of service providers on Sainik Suvidha Platform, Personal Information may be collected by respective service providers and such Personal Information shall be governed by their privacy policy. You may refer to their privacy policy and terms of service to understand how your Personal Information will be handled by such service providers.

Our services may include links to other websites or applications when you visit our Platform. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser or on the m-site you are redirected to), use of any Personal Information that you provide on these websites or applications is governed by the privacy policy of the operator of the application/website, you are visiting. That policy may differ from ours and you are requested to review those policies or seek access to the policies from the domain owner before proceeding to use those applications or websites. We do not accept any responsibility or liability for usage of your Personal Information by these third parties or their policies.

Your Consent

We process your Personal Information with consent. By using the Sainik Suvidha Platform or services and/or by providing your Personal Information, you consent to the processing of your Personal Information by Sainik Suvidha in accordance with this Privacy Policy. If you disclose to us any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy. Further, you agree and authorize Sainik Suvidha to communicate with you via channels like Phone calls and E-mail for the purposes set out in this policy, irrespective of your registration with any authorized DND registries.

Choice/Opt-out

We provide all users with the opportunity to opt-out of receiving any of our services or non-essential (promotional, marketing-related) communications from us, after setting up an account. If you want to remove your contact information from all our lists and newsletters or discontinue any our services, please click on the unsubscribe button on the emailers.

In case you receive a call for any specific Sainik Suvidha product/service you may opt-out from such calls by informing Sainik Suvidha’s representative during the call.

Data Security

• We use secure server connections for all our web pages to make it extremely safe for your data uses.
• Such server’s guarantees security of information transmitted through the web.
• However, the security for transmitting data over the web platform cannot be guaranteed for 100% due to the strange nature of the internet.

Using the Cookies

• When you browse through our website, it automatically stores your website cookies.
• The stored cookies will be only used to analyze our website performance and we will never share it with any third party in any circumstances.

Alteration in our Privacy Policy

• We reserve the full right to make any changes in our privacy policy in any circumstances without making any prior notice.
• Any changes made from our end will be posted on this page as soon as they come into action.
• It is your responsibility that you go through our policies before choosing any services with us.

Changes to Policy

Since our business changes constantly, so will our policies. We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time without any prior written notice to you. We may, however, reasonably endeavour to notify you of the changes, it is your responsibility to review the Privacy Policy periodically for updates/changes. Your continued use of our services/Platform, following the posting of changes will mean that you accept and agree to the revisions. We will never make changes to policies in order to make it less protective of Personal Information already shared by you.