GENERAL POLICY

This Privacy Policy (“Policy”) relating to the private practices of Finroot Innovations Private Limited (referred to as “Company”) describes how Passbook / www.passbook.ai (“Platform”, “we”, “us”, or “our”) collects, uses, discloses, and protects the personal and financial information of users (“you” or “your”) in accordance with applicable privacy laws and best practices. By accessing or using our Platform, you consent to the practices described in this Policy.

This Policy forms an essential part of the Terms and Conditions and other applicable terms on the Passbook Platform. It should always be read alongside the Terms and Conditions, specific product/service terms and conditions, disclaimers, declarations, and undertakings.

This Privacy Policy outlines the following: (i) the types of information collected from Users, including personal information and sensitive personal data or information; (ii) the purpose, means, and methods of collecting, using, processing, retaining, and deleting such information; (iii) the entities to whom we disclose this information; and (iv) the measures we take to protect Users’ personal information when they access the Platform.

Passbook Platform and its services are intended for individuals who are 18 years and older. If you are under 18, you must not access or use the platform, purchase any products or services, or submit any personal information. If you are acting as a guardian for a minor, you assert that you have the necessary authority to register or sign up for the Passbook Platform Services on their behalf. You agree to promptly provide or execute any additional document as requested to establish your status as a lawful guardian and to maintain your access to the Passbook Platform and Services. If we become aware that we have inadvertently collected such information, we will take necessary steps to protect or delete the information as appropriate. Please contact us immediately at contact@finroot.co.in if you believe we have any information from or about a child under 18.

PURPOSE OF PRIVACY POLICY

Your privacy is of utmost importance to us, and we are highly committed to protecting and securing your personal information. This Privacy Policy is applicable to all personally identifiable information (PII), sensitive personal data or information (SPDI), and other personal and non-personal data collected from you through the Passbook App.

This Privacy Policy is governed by the provisions of applicable laws in India, including but not limited to the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, along with other pertinent regulatory enactments. The terms “Personal Information” and “Sensitive Personal Data or Information” shall have the meanings ascribed to them under the statutes and rules, thereby ensuring the protection and confidentiality of your personal data in compliance with legal standards.

• CATEGORIES OF PERSONAL INFORMATION COLLECTED
• We collect Personal Identification Information and contact information such as Name, date of birth, gender, email-ID, Residential Address, phone number, your contacts and nominee details, photograph, and government-issued identification numbers (such as PAN, Aadhaar/Voter ID/Driving License, and/or Education Details) provided by you to us to avail services from Passbook.

 

• Financial information of the user’s Bank account details, transaction history, income details, investment history, and credit information which will be required for some of our services.

 

• Scanned copies of PAN card, Aadhaar card, passport, utility bills, or other documents may be collected for Know Your Customer (KYC) compliance.

 

• Account Information such as Username, password, and security questions for account access.

 

• Usage Data on how user interacts with the app, including login details, IP address, browser type, device information, and cookies.

 

• Details of transactions performed through the app, such as investment amounts, types of investments, and transaction dates.

 

• Upon receiving your explicit consent, the Passbook App may automatically access and read SMS text messages containing financial information related to transactions made using cards, banks, or wallets. These messages are received from service providers and banks (including retail outlets, financial institutions, and utility companies) on your mobile device. We do not access any personal SMS or OTPs which are not related to or actions initiated by Passbook or its affiliates.

 

• Records of communications with customer support, including chat transcripts, emails, and call recordings.

 

• Sample signature(s) or consent for processing your instructions received via our diverse payment and delivery channels.

 

You hereby consent to our retrieval or updating of your personal details from government agencies or regulated authorities such as KYC Registration Agencies, the Central Registry of Securitization Asset Reconstruction and Security Interest (CERSAI), Asset Management Companies, and Registrar and Transfer Agencies.

 

• UTILIZATION OF PERSONAL INFORMATION

Through Passbook App/www.passbook.ai, we ensure that your personal information is used responsibly and transparently. Here is how we utilize the personal information collected from you:

• We collect your name, contact details, and identification information to create and maintain your account. This includes verifying your identity, managing account preferences, and providing personalized services.
• Your financial information, including income, expenses, assets, and liabilities, is used to analyze your financial situation. This analysis helps us provide personalized investment information, financial planning recommendations, and portfolio management services.
• Information about your transactions, such as purchases, sales, investments, and withdrawals, are used to process these transactions efficiently and accurately. This includes ensuring compliance with regulatory requirements and monitoring for fraudulent activities.
• We use your contact information to communicate important updates, notifications, and account-related information. This includes proactive notifications and reminders about your upcoming dues (Loan EMI, insurance premiums, etc.), responding to your inquiries, providing customer support, and resolving issues related to your account or transactions.
• We collect and use your personal information to comply with applicable laws, regulations, and industry standards. This includes KYC (Know Your Customer) verification, anti-money laundering (AML) checks, tax reporting, and other legal obligations.
• Analyzing usage patterns and feedback helps us enhance our app/website’s functionality, user experience, and service offerings. This may involve conducting research, performing analytics, and developing new features based on user preferences and behaviors.
• With your consent where required, we may use your information for targeted marketing, personalized experiences, and offering relevant products or services that may interest you.
• Protecting your personal information is our priority. We employ security measures to safeguard against unauthorized access, misuse, or loss of your data. This includes encryption, access controls, and regular security audits.

By using our app/website, you consent to the collection, processing, and use of your personal information as outlined above.

• DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

 

We may share your personal information with third parties as necessary to provide our services and ensure the effective operation of the Wealth Management Platform. The third parties we may disclose your information to include:

1. Service Providers: Third-party service providers who perform functions on our behalf and your behalf, such as payment processing, data aggregation, data analysis, marketing, customer support, legal or financial consultation, service providers (e.g., loan service providers, insurance service providers, FD service providers), Banks, and other institutions may have access to your information. We ensure that all third-party partners are bound by confidentiality agreements and comply with applicable data protection standards.
2. Regulatory Authorities: We may disclose your information to regulatory bodies, law enforcement agencies, or other governmental authorities as required by law, regulation, or in response to official requests.
3. Business Partners: We may share your information with our business partners, affiliates, or other entities with whom we collaborate to provide products or services. These partners are obligated to maintain the confidentiality of your information and use it in accordance with this Privacy Policy.
4. Transaction Processing: To facilitate transactions initiated through the Wealth Management Platform, we may share your information with banks, financial institutions, or other relevant third parties.
5. Marketing and Advertising: With your consent, we may share your information with third parties for marketing and advertising purposes to deliver relevant advertisements and promotional materials.
6. Professional Advisors: We may disclose your information to our professional advisors, including lawyers, accountants, and auditors, to ensure compliance with legal and regulatory requirements and to protect our legal rights.
7. Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of our assets, your personal information may be disclosed to the relevant third parties involved in the transaction. Appropriate measures will be taken to ensure the confidentiality and protection of your information in such circumstances.
8. We are committed to ensuring that any third party with whom we share your personal information adheres to strict privacy and security standards to protect your data.
   

 

• COLLECTION AND USE OF NON-PERSONAL DATA

At Passbook App/ www.passbook.ai, we collect non-personal data to enhance our services and understand user behavior. Non-personal data, which cannot identify an individual, includes:

 

1. a) Device Information: Details about the device used, such as type, model, OS, IMEI, SIM Card and browser type. 
2. b) Usage Data: Information on how you interact with our platform, including pages visited and time spent. 
3. c) Performance Data: System logs, error reports, and usage statistics. 
4. d) Aggregated Data: Anonymized data combined from multiple users for statistical analysis.

 

We use non-personal data to improve user experience, analyze user behavior, monitor platform performance, and conduct research.

• SECURITY OF USER INFORMATION

We secure user information by using industry-standard encryption protocols to protect data transmission and storage. Access to your personal information is restricted to authorized employees and data processors only who are obliged to respect the confidentiality of user personal information. Additionally, we conduct regular security assessments and ensure our secure cloud partners maintain robust firewalls, secure networks, and intrusion detection systems to prevent unauthorized access.

• DATA RETENTION

 

We retain your personal data in compliance with the Prevention of Money Laundering Act 2002, SEBI (Investment Advisors) Regulations, 2013, or any other applicable law. Your data is kept for as long as necessary to fulfil legal obligations and manage transactions, after which it is securely disposed of unless required for record retention by applicable laws.

• COOKIES

 

Passbook App/ www.passbook.ai uses cookies to enhance your experience and provide personalized services. Cookies enable website functionality, analyze usage patterns, and deliver targeted content.

• ACCOUNT DELETION

 

You may request the deletion of your account with Passbook/Passbook.ai at any time by writing to us at contact@finroot.co.in. If you wish to rejoin, please create a new account.

• POLICY UPDATES

We may update this Policy to reflect changes in our practices or legal requirements. We will notify you of any significant changes via email, in-app notifications, or on our website. Continued use of the Platform following such updates constitutes your acceptance of these changes.

 

CONTACT US

 

If you have any questions or concerns about this Privacy Policy or our data practices, please contact our support team at privacy@finroot.co.in and contact@finroot.co.in.

 

GRIEVANCE REDRESSAL

 

Any complaints or concerns with regards to the content on the Passbook Platform and/or comment and/or breach of these terms and/or to report any abuse of law, shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email to:

The Grievance Officer, Finroot Innovations Private Limited.
www.passbook.ai
grievance@finroot.co.in

 

We request you to provide the following information in your complaint:

• Identification of the information provided by you.
• Clear statement as to whether the information is Personal Information or Sensitive Personal Information.
• Your address, telephone number, or e-mail address.

 

By using our Platform, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms. Thank you for trusting PASSBOOK.