PRIVACY AND SECURITY POLICY
INTRODUCTION:
Mishutt Financials Private Limited acknowledges the expectations of its customers regarding privacy, confidentiality and security of personal information that resides with the Mishutt Financials. Keeping personal information of customers secure and preventing any misuse thereof, is therefore, a top priority of Mishutt Financials.
We state that Mishutt Financials is strongly committed to protect the privacy of its customers and has taken all necessary and reasonable measures in line with the best industry practice to protect the confidentiality of your personal information and its transmission through our website.
This Privacy & Security Policy (hereinafter referred to as “Policy”) therefore, explains how we protect your personal information provided to us on our website i.e. www.mishutt.com(hereinafter referred to as “Website”) and how we use that information in connection with the service offered through the Website (hereinafter called as "Service") and must be read in conjunction with our General Terms of Use.
This Policy is published and shall be construed to be in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data of Information) Rules, 2011 under the Information Technology Act, 2000 and other applicable laws that require publishing of the privacy notice for collection, usage, storage, disclosure and transfer of sensitive personal data or information.
PERSONAL INFORMATION:
Personal Information (“PI”) means any information/ documents/ details that relates to a natural person, which either directly or indirectly in combination with other information available with Mishutt Financials, can identify such person.
APPLICABILITY:
(i) This Policy applies to the PI such as details pertaining to your name, parentage, marital status, nationality, state/city of residence, residential address, e-mail address, date of birth, gender, contact number/mobile number, user ids, passwords, recent photograph, signature image, income proof, PAN, credit score, credit information report, e-KYC through UIDAI, Aadhaar based e-Sign and such other Know Your Customer (KYC) documents like address proof, identity proof, officially valid documents/details (OVDs) accepted for concluding a financial transaction, which may be shared/ uploaded by you, as and when you avail any products and/or service through usage of the Website and to which Mishutt Financials may become privy to.
(ii) By visiting and/or using our Website, you agree to this Policy. Further, this policy applies to all current and former visitors to the Website. It is strongly recommended for you to return to this page periodically to review the most current version of the Policy.
(iii) Mishutt Financials reserves the right at any time, at its sole discretion, to change or otherwise modify the Policy without prior notice, and your continued access or use of this Website signifies your acceptance of the updated or modified Policy. However, if we make any material change to the Policy, we will notify you by e-mail (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective.
EXPRESS CONSENT:
(i) You while providing your details/documents over the Website, including but not limited to PI as mentioned hereinabove, expressly consent to Mishutt Financials (including its marketing channels and business partners) to contact you through SMS, call and/ or e-mail and to follow up calls in relation to the services provided through the Website, for imparting product knowledge, offering promotional offers running on Website & various other offers offered by its business partners.
(ii) The usage of the Website may also require you to provide consent for keying in/ uploading your PI (including but not limited to user ids and passwords), as may be necessary to process your application through the Website. Any PI which requires to be keyed in/ uploaded is required for enabling hassle free, faster and paperless (to the extent possible) processing of applications for financial products so opted/ availed by you.
(iii) You hereby authorize and expressly consent us to share your PI with third parties including but not limited to Credit Information Companies (“CIC”) to do an aggregate check of your credit profile for Mishutt Financials to send you targeted communications and offers.
(iv) If you are no longer interested in sharing your PI, please e-mail your request at: privacy@mishutt.com. Please note that it may take about 72 business hours to process your request. In furtherance to your usage of the Website, you expressly waive the Do Not Call (DNC) / Do Not Disturb (DND) registrations on your phone/mobile numbers for contacting you for such purpose and usage. Hence, there will be no DNC / DND check required for the number you may have left on our Website. Such modes of contacting you may include sending SMSs and/ or telephonic calls.
(v) Mishutt Financials reserves the right (and you expressly authorize Mishutt Financials) to share or disclose your PI when Mishutt Financials determines, in its sole discretion, that the disclosure of such information is necessary or appropriate under the law for the time being in force.
CREDIT INFORMATION REPORT
(i) Your Credit Information (credit score and credit information report) is procured through a 'soft search' of your credit records with Credit Information Companies “CICs” and Mishutt Financials has no control over the content or accuracy of information provided in your credit information by CICs. Mishutt Financials gets this information from CIC for and on your behalf only when you agree to appoint Mishutt Financials as your lawfully appointed authorized agent/ representative for collecting your credit information from CICs. By consenting to use and avail your credit information report through Mishutt Financials, you agree that Mishutt Financials and CICs shall be entitled to rely on your authorization and consent granted by you to Mishutt Financials.
(ii) Availing your credit information through Mishutt Financials is subject to your passing of appropriate identity authentication for security and privacy purposes. Mishutt Financials shall not notify you the reasons if you are unable to pass such identity authentications and not able to view and/or use your credit information.
(iii) Mishutt Financials may analyze and profile your credit information in order to assist you in being better informed about, understand and manage your credit score/rating, identify and inform you of credit products that are likely to be suited to your circumstances, to identify whether you may benefit from additional guidance concerning your credit score and steps you can take to improve your score and credit history etc. For more details please access Mishutt Financials’s Terms of Service for Credit Information Report.
MUTUAL FUNDS:
(i) Mishutt Financials collects, receives, possesses, stores, deals or handles PI received from investors/client/customers whether existing or prospective. Such PI may be as per the indicative list given below:
Bank Account details, change of bank account details or registration of multiple bank accounts etc through application forms;
Payment instrument details at the time of submitting application at the time of investment or as proof for carrying out change of bank account or any other details of debit card obtained (if any);
Generation and storing password (PIN) in encrypted form based on the request from the investor under the online mode of investments;
Demographic /Biometric information obtained, if any;
Demat Account details like beneficiary account no. etc.;
Annual Income and savings profile; and
Any other information as may be considered as PI.
(ii) The aforesaid information is being collected by Mishutt Financials to respond to your requests, to process the investment applications and to also ensure safe subscriptions/redemptions of mutual fund investments. Mishutt Financials may also call you to inform them with respect to the other products or services offered by its partner AMCs. The said information is also being collected to be compliant with the Know Your Client (KYC) norms under the Prevention of Money Laundering Act, 2002 (PMLA), the rules issued thereunder, and guidelines and circular on Anti- Money Laundering issued by SEBI and SEBI (Mutual Funds) Regulations, 1996 as amended till date.
OPT-OUT:
In case you do not want to be disturbed over telephonic calls, kindly fill up the details requested in the below table, including the details of the telephone number(s) on which you do not wish to be contacted and submit the same at privacy@mishutt.com from your email address registered at Mishutt Financials. The details that you provide through the opt-out email will remain confidential and once you have submitted the same to us, your telephone number(s) will be removed from all our telemarketing calling lists within 15 working days. We will make every effort to ensure that you do not get any further telemarketing calls on such telephone number(s). The details to be submitted for opting-out shall be as below:
Title*
First Name*
Last Name*
Country*
State*
City*
Email
Mobile Number #
Landline Phone Number
* Mandatory fields
# Please enter your 10-digit mobile number.
#Please specify your STD code.
PURPOSE AND USAGE:
(i) Mishutt Financials will not sell or rent your PI to anyone, for any reason, at any time. However, we will be sharing your PI with our affiliates and business partners including CICs, where we feel that you will be assisted better for the purpose of underwriting and approval of your credit card, loan or any other financial product transaction/related transaction; or for doing a check of your credit profile on your behalf and sending you targeted communications and offers. We assure that Mishutt Financials will always seek your consent to process certain types of information where it is legally required to do so. Mishutt Financials uses the PI collected to manage its business and offer you an enhanced, personalized online experience on its Website. By registering on the Website, you authorize Mishutt Financials to send SMS and e-mail alerts to you for its service requirements, including sending promotional e-mails and SMSs. Further, it enables Mishutt Financials to:
send you any administrative notices, offer alerts and other communications relevant to your use of the Service;
display tailored product offers to you and enable you to apply for certain products and services for which you have chosen to apply;
carry market research, project planning, troubleshooting issues, detecting and protecting against error, fraud or other criminal activity;
improve our Services and manage our customer relationships better;
enforce Mishutt Financials General Terms of Use;
comply with all applicable laws and regulations.
(ii) In the event that you access the Service as brought to you by one of our partners either through the Website or on being redirected from a co-branded URL or any other website , your name, e-mail address, mobile number, date of birth, employment type, residency status, income details/proofs, Form 26 AS, PAN, details of loan / credit card/ mutual fund applied for and loan, credit card and mutual fund status or any other financial product status may be provided to that partner when your application is submitted and whenever the status of application is updated. Mishutt Financials has a business relationship with these partners and you may not opt-out of sharing your information with these partners if you have applied via a co-branded URL or any other website or directly through the Website as the case may be.
(iii) For availing the Service such as applying for credit information report, loan, credit card, mutual fund or any other financial product we will require you to provide/upload on the Website the details such as a your name, parentage, marital status, email address, nationality, location, mobile number, PAN, employment & income details/proofs, Form 26 AS, recent photograph, signature image, other Know Your Customer (KYC) documents like address proof, identity proof and personally identifying information about a potential co-loan applicant (should you select this option), and to participate on our forum boards, you must provide a username for yourself.
(iv) You may opt out of location-based services at any time by editing the setting of your browser.
(v) In order to provide your bank statement or pay slip electronically along with your loan application, you also must provide your third-party account credentials ("Account Credentials") to allow Mishutt Financials to retrieve your account data at those other financial institutions ("Account Information") for your use. Your Account Credentials are only used once to retrieve your bank statements/pay slips, Form 26 AS and are not stored in our system. Mishutt Financials shall not be liable to you against any liability or claims which may arise out of such transactions being carried on your own accord.
(vi) We may also use third party service providers to provide the Service to you, such as sending e-mail messages on our behalf or hosting and operating a feature or functionality of the Service. Our contracts with these third parties outline the appropriate use and handling of your information and prohibit them from using any of your PI for purposes unrelated to the product or service they're providing. We require such third parties to maintain the confidentiality of the information provide to them.
DISCLOSURE / SHARING:
(i) Mishutt Financials does not disclose PI of a customer except as directed by law or as per mandate received from the customer / applicant. Upon your written request Mishutt Financials will provide you with information on whether we hold any of your PI. No specific information about customer accounts or other personally identifiable data is shared with third parties unless any one of the following conditions is met:
To help complete a transaction initiated by you;
To perform support services through a third-party service provider, provided it conforms to the Privacy Policy of the Mishutt Financials and your prior consent to do so is obtained;
You have specifically authorized it;
Where the disclosure is necessary for compliance of a legal obligation or as required by law, such as to comply with a subpoena, or similar legal process;
When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
(ii) There are number of products/services such as loans, credit cards, mutual funds, offered by third Parties on the Website, such as lenders, banks, credit card issuers. If you choose to apply for these separate products or services, disclose information to these providers, then their use of your information is governed by their privacy policies. Mishutt Financials is not responsible for their privacy policies. Mishutt Financials may share your data with other third parties, such as service providers, advertisers, Credit Information Companies, fraud prevention agencies, marketing channels, affiliates, without the need for additional consent from you.
(iii) Mishutt Financials shall not be held liable for disclosure of the PI when used in accordance with this Privacy Policy or in terms of the ‘General Terms of Use’ of Website or an agreement, if any, with the users of Website .
INTIMATION BY CUSTOMERS REGARDING CHANGE IN PERSONAL INFORMATION:
(i) If your PI provided to us when you had applied for a product on our Website changes, you may update it whenever you apply for a new product via our Website. To review and update your PI and to ensure that the same is accurate while your application is in process, you may contact us at support@mishutt.com. You will not be able to update the information you have provided in an application after a decision has already been made on it; however, you may create and submit a new application with your updated information.
(ii) Note: We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at support@mishutt.com. We will respond to your request within a reasonable timeframe. However, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.
RETENTION OF YOUR DATA
(i) Mishutt Financials will retain your information for as long as it is necessary for providing you the Services available on the Website or your request for termination of your account with Mishutt Financials, whichever is later.
(ii) Post termination of your account, Mishutt Financials may continue to use your anonymized data aggregated or in combination with anonymized data of other users. We use this aggregated anonymized data for data analysis, profiling and research purposes, for example to gain insights about our users and their profiles. We may keep your contact information along with your application details (if any) for fraud prevention purposes and for the exercise/ defense of a legal claim or for providing evidence in legal proceeding(s).
EMAIL & SMS COMMUNICATIONS FROM US AND OUR PARTNERS:
We provide our registered customers with periodic emailers and email/SMS alerts. We also allow users to subscribe to email newsletters and from time to time may transmit emails promoting Mishutt Financials or third-party products. Subject to the express consent clause above, Mishutt Financials’s Website subscribers may opt-out of receiving our promotional emails and terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related e-mails/SMS, such as e-mail/SMS alerts. The above services are also provided by our partners.
LOG FILES:
This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may use the collected log information about you to improve services offered to you, to improve marketing, analytics, or Website functionality.
TRACKING TECHNOLOGIES:
Mishutt Financials and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. To manage flash cookies, please visit the flash player support page.
BEHAVIOURAL TARGETING / RE-TARGETING:
We partner with a third-party service provider to either display advertising on our Website or to manage our advertising on other websites. Our third-party partner may use technologies such as cookies to gather information about your activities on this Website and other websites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
THIRD PARTIES WILL NOT BE GIVEN YOUR PERSONAL INFORMATION UNLESS YOU GIVE CONSENT TO MISHUTT FINANCIALS :
There are several products and services, such as credit information report, loans, credit cards, mutual fund and other financial products being offered by third parties on our Website, such as lenders, banks, credit card issuers and mutual funds (collectively "Offers"). If you choose to apply for these separate products or services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies. You should evaluate the practices of these external services providers before deciding to use their services. Mishutt Financials is not responsible for their privacy practices.
TESTIMONIALS, BLOGS AND OTHER FORUMS ON MISHUTT FINANCIALS WEBSITE:
(i) With your consent Mishutt Financials may post your testimonial along with your name. If you want your testimonial removed, please contact Mishutt Financials at support@mishutt.com.
(ii) If you use a blog, comments section or other public forum on Website, any information you submit there can be read, collected or used by other users and could be used to send you messages. Mishutt Financials shall not be held responsible for the PI you choose to submit in these forums.
ADDITIONAL POLICY INFORMATION:
(i) Widgets: Our website includes widgets, which are interactive mini-programs that run on our Website to provide specific services from another company (e.g. displaying the news, opinions, music, etc.). PI, such as your email address, may be collected through the widget. Cookies may also be set by the widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it and not by the Mishutt Financials.
(ii) Single Sign-On: You can log in to our Website using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain PI with us such as your sign-in information, name and email address to link between the sites. Social networking media services like Facebook & Twitter give you the option to post information about your activities on this Website to your profile page to share with others within your network.
(iii) Like Button: If you use the "Like" button to share something that item will appear on your Facebook profile page and on your friends’ newsfeed depending on your Facebook privacy settings. You may also receive updates in your Facebook newsfeed from this Website or item in the future. Facebook also collects information such as which pages you have visited on this and other sites that have implemented the "Like" button.
(iv) Links to 3rd Party Sites: Our Website includes links to other websites whose privacy practices may differ from those of Mishutt Financials. If you submit your PI to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
WE KEEP YOUR DATA SECURE:
(i) We follow generally accepted standards to protect the PI submitted to us, both during transmission and once we receive it. Since no method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, we cannot guarantee its absolute security. If you have any questions about security on our Website, you can contact us at privacy@mishutt.com.
(ii) We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Mishutt Financials online accounts and systems from unauthorized access.
(iii) When you register for the Service, Mishutt Financials requires a password from you for your privacy and security. Mishutt Financials transmits information such as your login credentials for Website or Account Credentials securely.
(iv) Our servers are in secure facilities where access requires multiple levels of authentication, including an identity card and biometrics recognition procedures. Security personnel monitor the facilities 7 days a week, 24 hours a day.
(v) Our databases are protected from general employee access both physically and logically. We encrypt your Service password so that your password cannot be recovered, even by us. All backup drives and tapes also are encrypted.
(vi) We enforce physical access controls to our buildings. No employee can put PI on any insecure machine (i.e., nothing can be taken from the database and put on an insecure laptop). We permit only authorized employees who are trained in the proper handling of customer information, to have access to aforesaid PI.
(vii) Mishutt Financials has been verified for its use of SSL encryption technologies. In addition, Mishutt Financials tests the Website using Acunetix scan for any failure points that would allow hacking. However, it is important to understand that these precautions apply only to our Website and systems.
ALL PRIVATE INFORMATION IS ENCRYPTED AND COMMUNICATED SECURELY:
All communications between your computer/mobile and our Website that contain any PI are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery.
YOU ARE RESPONSIBLE FOR MAINTAINING THE CONFIDENTIALITY OF YOUR LOGIN ID AND PASSWORD:
(i) You are responsible for maintaining the security of your login ID and Password and must not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at privacy@mishutt.com. We are not responsible if someone else accesses your account through the login credential they have obtained from you or through a violation by you of this Privacy and Security Policy or the Mishutt Financials Terms of Use.
(ii) If you have any security related concern, please contact us at privacy@mishutt.com. We will work closely with you to ensure a rapid and personal response to your concerns.
CONTACT US WITH ANY QUESTIONS OR CONCERNS:
If you have grievance or complaint, questions, comments, concerns or feedback in relation to the processing of information or regarding this Privacy and Security Policy or any other privacy or security concern, send an e-mail to privacy@mishutt.com.
The contact details of the communication address: Plot no.2/F,sector-5/C, Bokaro Steel City,Jharkhand- 827006.
NOTICE:
The effective date of this Policy, as stated below, indicates the last time this Policy was revised or materially changed.
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