Privacy Policy

Last updated on April 19, 2023

We, Gravity Hour Technologies Private Limited, (“Company”, “we”, “our”, “us”) are the owners of  the website www.myfolio.ai (the “Website”) and the application ‘Myfolio’ (the “Application”). The Website and Application are collectively referred to as the platform (the “Platform”). The Platform offers a secure digital vault to store financial and non-financial information (“Offerings”).  

The Company is committed to protecting your Personal Information and we respect your privacy and choices. This privacy policy (“Privacy Policy”) highlights our privacy practices, Personal Information that we collect and store about you through this Platform and also the Personal Information that you provide us while participating in our events and campaigns.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CLICKING ON THE CONSENT CHECK BOX, AND BY PROVIDING US PERSONAL INFORMATION, YOU CONSENT TO OUR USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY WITHDRAW YOUR CONSENT OR ALTERNATIVELY CHOOSE NOT TO PROVIDE YOUR PERSONAL INFORMATION ON THE PLATFORM. SUCH AN INTIMATION TO WITHDRAW YOUR CONSENT CAN BE PROVIDED BY EMAIL ON THE EMAIL ADDRESS BELOW.
IF YOU ARE ACCESSING THE PLATFORM ON BEHALF OF A THIRD PARTY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH THIRD-PARTY TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND, IN SUCH AN EVENT YOUR USE OF THE PLATFORM SHALL REFER TO USE BY SUCH THIRD PARTY. IF YOU DO NOT HAVE SUCH AN AUTHORITY (TO PROVIDE ANY PERSONAL INFORMATION OF A THIRD PARTY) OR DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, THEN YOU SHOULD REFRAIN FROM USING THE PLATFORM.

This Privacy Policy is an electronic record in the form of an electronic contract being compliant and construed in accordance with data protection laws of the applicable jurisdictions.
  1. I.Personal Information we collect and process and how we use it
    1. Personal Information that we process
For the purposes of this Privacy Policy, “Personal Information” is any data which relates to an individual who may be identified from that information, or from a combination of a set of data, and other information which is in possession of the Company.

For the purpose of this Privacy Policy, “User/s”, “you”, “your” shall mean and include individuals who visit, access and/ or use the Platform.

We may collect your Personal Information as a part of our Offerings, including but not limited to:
  1. your name, address, gender, email address, contact information,
  2. your family information, family member’s information, nominee information.   

In general, you may browse our Platform without providing any Personal Information about yourself. However, we may collect certain Personal Information such as
  1. Information that you provide on our Platform, including information you provide when you register on our Platform e.g. name, email address, residential address, designation, company, country and telephone number;
  2. Information about your computer and about your visits to and use of this Platform, such as your Internet Protocol (IP) address, demographics, your computers’ operating system, and browser type and information collected via cookies; 
    1. Use of your Personal Information
We use your Personal Information for the following purposes:
  • to provide better usability, troubleshooting and Platform maintenance;
  • to understand which parts of the Platform is visited and how frequently;
  • to create your user ID;
  • to identify you once you register on our Platform;
  • to contact you and respond to your questions or requests;
  • to provide access to desirable content based on your preferences;
  • to process and transfer the information to the nominee appointed by you at the time of registration of your account with us;
  • for internal record keeping; and
  • and to comply with our legal or statutory obligations.
 
    1. Legal basis of the processing
We process your Personal Information when it is necessary for the performance of a contract to which you are the party or in order to take steps at your request prior to entering into a contract. This applies in any case where we provide services to you pursuant to a contract, such as when you use our Platform or process your registration on the Platform. If you do not provide the Personal Information that we need in order to provide our services, we will not be able to provide our services to you. We process your Personal Information for the performance of a contract in the following circumstances:
  • to provide better usability, troubleshooting and site maintenance; and
  • to create your user ID.
We process your Personal Information when it is necessary for the purposes of a legitimate interest pursued by us or a third party (when these interests are not overridden by your data protection rights). This applies in the following circumstances:
  • to identify you once you register on our Platform; and
  • to contact you and respond to your questions or requests;
  • to understand which parts of the Platform are visited and how frequently; and
  • to provide access to desirable content based on your preferences.
  1. Consequences of not providing Personal Information
If you choose not to provide your Personal Information that is necessary to process your request, we may not be able to provide the respective Offerings.
 
  1. Data recipients, transfer, and disclosure of Personal Information:
The Company does not share your Personal Information with third parties for marketing purposes without seeking your prior permission. 
We share your Personal Information within 
  • our Company or with any of its subsidiaries;
  • Business partners;
  • Service vendors;
  • Authorized third-party agents; or 
  • Contractors.
We do not share your  Personal Information (User Information pursuant to Clause 6 of the terms of use) to any parties except the nominee appointed by you at the time of registration of your account with us  pursuant to the terms of service.
When required, we may disclose Personal Information to law enforcement bodies or regulatory authorities, in order to comply with legal obligations and applicable laws.
  1. Use of cookies:
We use cookies and/or similar in-house and third-party tracking tools to track user traffic patterns.
      1. What are Cookies?
Cookies are alphanumeric files which are placed on to your device when you visit a website. It allows us to recognize your device and store some information about your preferences or past actions, analyze trends, to learn about our user base, operate and improve our Offerings and provide you with a better experience when you visit our Website.
      1. Types of Cookies Used
  2. Permanent cookies – Permanent cookies help us recognize you as an existing user, so it’s easier for you to return to the website without signing in again. After signing in, the permanent cookies stay on your browser and will be read when you return to our sites. These remain on your computer/device for a pre-defined period.
  3. Session cookies – Session cookies only last for as long as the session exists (they get erased when the user closes the browser).
As for the domain to which it belongs, there are either:
    • First-party cookies: These cookies are set by the web server of the visited page and share the same domain.
    • Third- party cookies: These cookies are placed by third party on your device and may provide information to us and third parties about your usage of the website.
    • Analytical Tools:
Google Analytics: We use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, text files that are stored on your computer and enable analysis of your use of the website. The information generated by the cookies about your use of the website are usually transferred to a server of Google in the US and stored there. We do not control third party cookies.  You can also prevent the data generated by the cookie and related to your use of the website to Google and the processing of these data by Google, by visiting the following link. (https://tools.google.com/dlpage/gaoptout)
      1. Use of Cookies
We use Personal Information captured through cookies to make your interaction with us faster and more secure. They may be used for the following purposes:
  1. Preferences – Cookies allow the Website to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in. Remembering your preferences enables us to personalize and display advertisements and other content for you.
  2. Security/Optimization – Cookies allow us to maintain security by authenticating users, preventing fraudulent use of login credentials and protect user data from unauthorized parties. We may use certain types of cookies to allow us to block many types of attacks, such as attempts to steal content from the forms present on the website.
  3. Processing – Cookies enable the website to work efficiently. Basis such cookies, we are able to deliver services that a website visitor expects, like navigating around web pages or accessing secure areas of the website.
  4. Advertising – We use cookies to make advertising more engaging for our users. Some common applications of cookies are made to select advertising based on what’s relevant to you, to improve reporting on campaign performance and to avoid showing ads you would have already seen. Cookies capture information about how you interact with the website, which includes the pages that you visit most.
  5. Communication – We may use information collected via cookies to communicate with you, for sending newsletters, seeking your opinion and feedback and providing you services and promotional materials.
  6. Analytics and Research – We may use cookies to better understand how people use our Offerings so that we can improve them.
      1. Disabling Cookies
You can decide whether to accept or not to accept cookies. You can disable the cookies by adjusting the settings on your browser (see your browser Help for how to do this). Disabling cookies may affect the functionality of our website.
  1. Access, correction, objection of your Personal Information:
You have the right to access, correct, delete or transfer your Personal Information that we hold, including your profile and preferences. You also have the right to object to certain processing and, where we have asked for your consent to process your Personal Information, to withdraw this consent. Where we process your Personal Information because we have a legitimate interest in doing so (as explained above), you also have a right to object to this. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your Personal Information.
You can assert your rights in the corresponding sections where such information was provided or by contacting us at support@myfolio.ai.
 
  1. Data security
We have implemented reasonable and appropriate security practices and procedures including administrative, physical security, and technical controls in order to safeguard your Personal Information.
 
  1. Data retention
Personal Information will not be retained for a period more than necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by law or for directly related legitimate business purposes.
 
  1. Information for EU and UK Visitors
Residents of the European Union (“EU”) and United Kingdom (“UK”) should note that this Privacy Policy has been updated in accordance with the requirements of the EU General Data Protection Regulation (the “GDPR”) and the UK GDPR, the United Kingdom Data Protection Act 2018, the Privacy and Electronic Communications Regulations, and any regulation superseding any of the foregoing (“UK Privacy Laws”). As per the provisions of the GDPR and UK Privacy Laws we shall be considered the Controllers of the Personal information collected as a result of your use / access of the Platform and Processors of the Personal information collected as a result of your use / access of the Services.
Legal Basis (for EU residents and UK residents): We will not process your Personal Information without a lawful basis to do so. We will process your Personal Information only on the legal bases of consent, contract, or on the basis of our legitimate interests, provided that such interests are not overridden by your privacy rights and interests.
Transfer of your personal information across borders (for EU Residents): The Personal Information we collect (of EU and UK residents) is stored on servers located in the EU region. Personal Information might be processed outside the EU and UK. We collect and transfer Personal Information outside the EU and UK in accordance with the provisions of the GDPR and UK Privacy Laws. If you have questions, please contact support@myfolio.ai.
Your Rights (For EU and UK Residents):
You have the right to request us:
  1.  to let you know what Personal Information belonging to you,
  2.  we hold in our possession,
  3. withdraw consent at any time where we are relying on consent to process your Personal Information,
  4. right to have us rectify or modify any such Personal Information,
  5. right to have us erase/delete your Personal Information,
  6. right to restrict us from processing such Personal Information,
  7. right to object to our use of your Personal Information,
  8. you have the right to lodge a complaint with a data protection authority.
UK residents have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. We may need to request specific information from you to help us confirm your identity or also contact you for further information in relation to your request. If you would like to exercise ANY of these rights, please contact support@myfolio.ai.
Governing Laws: For any EU and UK residents, this Privacy Policy shall be governed respectively by the provisions of the GDPR and UK Privacy Laws.
  1. Linked website/ platforms
Our Platform may contain links to third-party website/ platforms and services. However, we are not responsible for the privacy statements, practices, or the contents of such third-party website/ platforms.
 
  1. Governing Laws
This Privacy Policyshall in all respects be governed by and construed and enforced in accordance with the laws of Republic of India and the courts in Pune shall have an exclusive jurisdiction to adjudicate any subject matter under this Privacy Policy.
 
  1. How to contact us
    1. If you wish to exercise your rights of access, rectification, erasure, restriction, data portability or the right to object to the processing of Personal Information or if you have any questions or requests regarding this Privacy Policy, our processing or wish to file a complaint, you can contact our grievance officer, Asmita Manjarekar at support@myfolio.ai
    2. We will investigate all complaints and if a complaint is found justified, we will take all reasonable steps to resolve the issue.
    3. To guard against fraudulent requests, we may require sufficient information to allow us to confirm that the individual making the request is authorised to do so.
  2. Updates to this Privacy Policy
We may change the data privacy practices and update this Privacy Statement as and when the need arises, and the same will be made available on the Platform. But our commitment to protect the privacy of Platform users will continue to remain.
 
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