otto.money - Privacy Policy
This is the Privacy Policy (“Policy”) of Woyage AI Solutions Private Limited, a company incorporated under the Companies Act, 2013 and having its registered office at Villa 260, Prestige Lakeside Habitat, Varthur Main Road, Bengaluru. 560087 (hereinafter referred to as “Company/us/we”). Thank you for using our platform, Otto Money, available as the application named Otto Money and website otto.money (the “Platform”). This Policy discloses the Company’s information practices for this Platform and related services (“Services”) provided by us and our third-party partners (“Partners”), including the nature of information being collected, the method of such information collection, use of such information, and how the Company handles your information.
We collect personal and sensitive information you voluntarily provide to us for purposes of using the Platform, such as your name, email address, title, organization name, telephone number, mailing, password, address, billing information, and any other information necessary for you to use the Platform. Additionally, when you visit the Platform, we automatically collect information like your IP address, browser type, operating system, referring URLs, and device information. We also collect information about your interaction with the Platform, including your project data, stored on AWS, and site usage statistics, which help us enhance productivity and improve our services. This data helps us understand user interaction with our Platform and improves our services (“Personal Data”).
By using the Platform, you expressly consent to providing us with your information and authorize us to use and disclose such information as provided in this Policy. This Policy applies to all users of the Platform, whether casual users or registered users, including customers and partners who engage in transactions on the Platform. When you consent to the collection of your information, it shall be interpreted that you have read this Policy and Terms of Use available on the Platform, and you have provided your explicit consent after fully understanding the terms and conditions herein.
1. Policy & Purpose
This privacy policy is adopted by Woyage AI Solutions Private Limited for its platform, Otto Money, and governs the collection, use and transfer of any information capable of identifying a person (“Personal Information”) of individuals accessed or shared with us by virtue of use or access of our mobile application, and/or our website (referred to as the “Platform”).
Unless specified otherwise, this Privacy Policy applies only to the Platform and services, features, software, and functionalities offered by us, via the Platform. For the purposes of this Privacy Policy, “Sensitive Personal Data” or “Sensitive Information” means Personal Information, that consists of (i) passwords, (ii) financial information, such as bank account, debit or credit card details, (iii) physical, psychological and mental health condition, (iv) sexual orientation, (v) medical records and history, (vi) biometric information, (vii) official identifier, (viii) sex life, (ix) genetic data, (x) transgender status, (xi) intersex status, (xii) caste or tribe (xiii) religious or political belief or affiliation, (xiv) any detail relating to the above as provided to the body corporate for providing a service, and (xv) any of the information received under each of the aforesaid heads by the body corporate for processing, or to be stored or processed under a lawful contract. This Privacy Policy incorporates the requirements under the Information Technology Act, 2000 and applicable rules thereunder.
2. Our Business & Policy Applicability
Woyage AI Solutions Private Limited is engaged in the business of providing specialized information analytics services for investment data available in the public domain. By visiting the Platform, merchants, and customers (hereinafter referred to as “Users”/ “you”/ “your”) can access our services, which include investment tracking tools, stock-related information and tools, mutual fund and personal finance-related information and tools and premium features such as portfolio planner, portfolio analysis, analyst's choice, premium coverage stories, alert tools, risk assessment and such other tools that may be added from time to time serviced and provided by us or our Partners. By accessing the Platform, you expressly consent to be bound by this Privacy Policy and are accepting the measures, protocols and practices involving the collection, use and transfer of Personal Information, including Sensitive Personal Data or Information, collected from you, as set out hereinbelow. This Privacy Policy does not apply to mobile applications or websites which are not owned or controlled by Woyage AI Solutions Private Limited, including third-party links and applications with which you may interact while using the Platform. We will not assume any liability for any harm caused to you by accessing any third-party websites or links advertised on the Platform.
3. Collection of Personal Data
By accepting this Policy, you authorize the Company to process any information you provide on our Platform or in other ways. To register as a user, we require basic information such as your name, email address, organization, and billing details. We ensure that this information is not sold or shared with any unauthorized third parties.
When you access the Platform for certain activities or to avail our services, we may ask you to provide Personal Information about yourself and/or family members for whom you seek investment advice. The data collected and its purpose are as follows:
Data Collected | Purpose |
|---|---|
Address | KYC/payment processing |
Date of Birth | To validate KYC (Know your customer) status of the user from the central KYC registry. To determine tax status of the Users to calculate the tax incidence on their investments |
PAN/AADHAR NUMBER | To validate KYC (Know your customer) status of the user from central KYC registry / Electronic communications / Fetching and aggregating the User’s financial information/Digital Signature. |
Phone Number | Creation of account/ verification of identity / Electronic communications / Fetching and aggregating the User’s financial information/Payment processing |
Email address | Creation of account/ verification of identity/ Electronic communications / Fetching and aggregating the User’s financial information/Payment processing |
Name | Creation of account/Payment processing / Fetching and aggregating the User’s financial information |
You acknowledge that any Personal Information pertaining to family members will be provided by you only after obtaining their consent to share such Personal Information with us. Woyage AI Solutions Private Limited shall not be responsible for obtaining any consent from your family members or any other person for whom you seek investment advice.
Apart from the aforementioned Personal Information, other Personal Information such as age, gender, marital status, educational qualification, occupation, household income, value of financial/non-financial assets and liabilities will be solicited for yourself and/or family members for whom you seek investment advice, for the purpose of account creation and/or risk assessment as mandated by the Securities and Exchange Board of India. While most information we collect can be shared at the discretion of the Users, some Personal Information is required to be shared to enable the User to access certain services provided on the Platform. If you do not provide the information required by Woyage AI Solutions Private Limited to provide you with a specific service or feature, you will not be able to access such service or feature of the Platform.
If you send us personal correspondence, such as emails or letters, or if other Users or third parties send us correspondence about your activities on the Platform, we may collect such information into a file specific to you. Upon contacting Woyage AI Solutions Private Limited, we may also use your contact information to send you magazines and books, updates regarding our products and inform you about alterations or upgrades to our services, features, software, and functionalities offered by us, via the Platform. You may opt out of receiving any non-essential communications from us by contacting our Grievance Officer.
A. Sensitive Personal Data or Information Collected
We shall always take your express consent before collecting any Sensitive Personal Data or Information. We are committed to keeping all such Sensitive Personal Data or Information safe at all times and ensure that such data/information is only transacted provided the highest possible degree of care available under the technology presently in use. Woyage AI Solutions Private Limited will not use your Sensitive Personal Data or Information for any purpose other than for such specific purposes as you have expressly consented to its use.
Upon registering on the Platform, you authorize Woyage AI Solutions Private Limited to automatically fetch and store, and/or you may choose to provide, from time to time, details of your (i) investment holding in stocks, mutual funds, public provident fund, national pension system, fixed income instruments, (ii) Balances in your bank accounts, (iii) permanent account number, (iv) permanent retirement account number, (v) demat account number, (vi) folio number, (vii) date of transactions, (viii) details of broker, and (ix) investment preferences with respect to duration, amount of investment each month or lump sum and tax savings requirements, which are classified as Sensitive Personal Data or Information. Any payment data may need to be retained only within India to comply with directives of the Reserve Bank of India that apply to the payment service providers we engage to provide the services. Where we permit any third parties to collect and use your Sensitive Personal Information, we shall follow the obligations set out in Part V below and (i) ensure that such third parties maintain the same security standards that are adhered to by us for the protection of your Sensitive Personal Information and (ii) take reasonable measures to ensure that the third parties do not disclose the Sensitive Personal Information unless such disclosure has been expressly consented to by you.
Non-Personal / Aggregated Data
Apart from the information you provide to us, we may also collect information related to your browser, internet protocol address, browser history. We use this information to understand Users’ demographics, interests, and behaviour to better understand, protect and serve our users. This information is compiled and analyzed on an aggregated basis.
B. IP Address & Location Information
When you visit our Platform, Company collects your IP address to help diagnose problems, administer and tune the operation of the Platform, track traffic, and gather demographic information. This data is used to improve our Platform, products, and customer service. We may collect and use your location information to enhance the functionality of the Platform. By using our Platform, you consent to this data collection.
C. Cookies and Web Beacons
Company collects data through cookies and other monitoring technologies to enhance your browsing and shopping experience on our Platform. ‘Cookies’ are small pieces of information that are stored by your browser on your computer’s hard drive to collect information about your activities on our Platform. We may authorize third parties to use cookies and other monitoring technologies to compile information about the use of the Platform or interaction with advertisements that appear on the Platform. We do not have access or control over these cookies. We do not link the information we store in cookies to any personally identifiable information you submit while on the Platform. We use session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You are always free to decline cookies if your browser permits, although, by declining the use of cookies you may not be able to use certain features on the Platform.
4. How We Use the Information We Collect
Company owns all the information collected through the Platform. We may use the information described above to:
Verify your identity.
Create and manage your account.
Send you offerings of products or services and update you on special offers available on the Platform. You may unsubscribe from these communications anytime.
Monitor and improve the Platform by calculating visitor statistics, identifying geographical locations, demographics, preferences, and behavior. Aggregated Platform usage statistics may be shared with advertisers or other third parties.
Administer participation in special events, contests, surveys, and market research.
Respond to your queries.
Operate, evaluate, and improve our business. This information may also be used when you contact Company through chat or email. Company reserves the right to include your email ID in marketing communications.
5. Sharing of Information
We will not disclose or transfer any of your Personal Information or Sensitive Personal Data or Information to any third parties except as explicitly provided in this Policy or where we have your consent to do so. We will only share your Personal Information or Sensitive Personal Data or Information with third-parties in the following circumstances:
A. Provision of Services:
Where any service requested by you involves a third party, such information, as is reasonably necessary for Woyage AI Solutions Private Limited to carry out a service request involving such third party, may be shared with the third party. We may also engage with other entities to perform functions including but not limited to analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing card payments, and providing customer service. Such companies shall be granted access to the Personal Information needed to perform their functions and include:
Third-Party Data Recipient Entity Name | Service/Function |
|---|---|
Woyage AI Solutions Private Limited | Providing additional non-personalized information regarding various funds and stocks at no cost to the User. |
CDSL Ventures Ltd. (CVL) | For verifying, validating and conducting KYC of the user |
Digiotech Solutions Private Limited (Digio) | Enabling verification, validation and KYC of the user |
MF Utilities India Pvt. Ltd./BSE Administration & Supervision Limited (BASL) | Facilitating mutual fund transactions |
CAMS Financial Information Services Pvt Ltd / Sterling Software Private Limited | For Fetching and aggregating the User’s financial information |
Razorpay Software Private Limited | Facilitating payment transactions |
Woyage AI Solutions Private Limited takes efforts to ensure that any agent or third party that Woyage AI Solutions Private Limited engages comply with the same security standards as Woyage AI Solutions Private Limited for the protection of your Personal Information and Sensitive Personal Data or Information in Woyage AI Solutions Private Limited’s custody.
Any personal information, if collected, will be passed on to our trusted Partners and service providers who shall need access to the information upon your placing an order with us. We use trusted third-party service providers to perform certain services on our behalf, including for the purposes of payment processing, data storage/management, web hosting, web analytics, fulfillment, marketing, mailing, and emailing. These Partners and service providers only receive personal information if such information is needed to perform their function(s), and they are not authorized to use any personal information for any other purpose(s) other than the purpose(s) set forth by Company.
B. Woyage AI Solutions Private Limited and its Affiliates:
Your Personal Information may be shared with our group companies, affiliates, and companies having the same promoters as us. Such persons will only use your Personal Information in accordance with this Privacy Policy.
C. Law Enforcement:
We may also use and disclose the information you provide as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with investigations or legal processes; (c) to respond to requests from public and government authorities, including authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to defend our business, or those of any of our affiliates from third-party claims; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies in law or equity to limit damages that we may sustain. We may disclose your personal information to comply with legal obligations, regulatory requests, or court orders, and to protect the rights and safety of the Company, its users, or the public.
D. Change in control:
We may also share your information with third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire, or form a joint venture with, such third party; or (b) sell or transfer any of Woyage AI Solutions Private Limited’s businesses or any of its assets, in which case the information we hold about you may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer. Your personal information may be disclosed as part of any merger, sale of Company assets, acquisition, or in the event of insolvency, bankruptcy, or receivership.
6. Storage & Security
All information provided by you is stored and retained on a secure server located in Noida, India. Woyage AI Solutions Private Limited maintains managerial, technical, operational, and physical security practices and procedures to protect data from misuse and unauthorized access and maintain the accuracy of data (“Security Practices”). Such Security Practices involve measures including, but not limited to encryption, firewalls, password protection, limitation of access to specified personnel on a need to know basis, de-identification and encryption and other physical security measures to guard against unauthorized access to the server and systems and information residing on such server and systems. Woyage AI Solutions Private Limited’s Security Practice protects against unauthorized access to, or unauthorized alteration, disclosure or destruction of the information. Woyage AI Solutions Private Limited’s Security Practices are commensurate with the information assets being protected and with the nature of the business. By using the Platform, you accept that the Security Practices and procedures mentioned above, which are designed to protect the information provided by you, are reasonable. Woyage AI Solutions Private Limited has deployed appropriate physical, electronic, and managerial procedures required under the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, to safeguard and help prevent unauthorized access, maintain data security, and avoid loss of User information. However, transacting over the internet has inherent risks and absolute security of data in the online sphere cannot be guaranteed, therefore, we do not assume any responsibility for any transmission of your information which you do at your own risk and/or for disclosure of your information due to errors in transmission and/or unauthorized acts of third parties.
The Company has implemented reasonable security practices, such as:
encryption of personal data;
use of proper technical and organisational measures across the business;
hosting personal data on Google’s cloud platform (“GCP”), which provides us with a wide range of resilience, scaling and security features. GCP is accredited under ISO 27001 and Sarbanes-Oxley (SOX);
use of secure socket layer (SSL) when dealing with third parties, the standard security technology for establishing an encrypted link between a web server and a browser;
sharing minimal data with third party services on a need to know basis (e.g., when requested by the user);
reflecting our commitment to high security standards in protecting your information.
7. Your Rights
We do not keep your data for longer than is necessary unless we are required to do so under applicable law. We will use your Personal Information only for so long as is necessary:
to achieve the purposes that have been specifically identified in this Privacy Policy or such purposes as have been identified in any agreement entered into with you;
as required by applicable laws and regulations, or as may be required for evidentiary purposes;
as deemed necessary for tax, fraud control, or mitigation, and to conduct a defence in relation to any disputes or claims whether potential or actual (taking into account statute of limitations under applicable laws).
You can review, modify, and delete the information you have provided to us at any time by accessing the Platform and/or withdraw your consent from allowing us to collect, process or transfer your information by contacting Our Grievance Officer. Please note that if you withdraw your consent, we may be constrained to withdraw those features, functionalities, services etc. which cannot be provided, without the information you seek to withdraw consent for, or delete from our records. Please note that your requests with respect to your data shall not be complied with if it adversely affects another user, or prejudices such user’s rights. Your right to withdraw consent relates to any further collection or processing, of your Sensitive Data, however such withdrawal of consent shall not: (i) be retrospective or require the deletion of records required for statutory purposes; or (ii) operate where required for the discharge of ongoing contractual obligations unless the contract under which the Sensitive Data is required to be collected is also terminated with the request for withdrawal of consent to collect such Sensitive Data. Your data will be erased/deleted when it has served the purpose for which it was being collected and is no longer necessary, where consent has been withdrawn, or where retention of such data is contrary to or prohibited by applicable law.
Upon request, we will remove your personal information from our database. However, our Partners may require access to your personal information in order to provide you with the Services and such removal of your personal information from our database may make you ineligible to avail the Services. Upon written request, you may access and/or request that any erroneous information about you be corrected. You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at the e-mail address below. The Platform may, from time to time, contain links to and from the platforms, websites or applications of our partner networks, advertisers and affiliates. If you follow a link to any of these platforms, websites or applications, please note that these platforms, websites or applications have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to them.
8. Grievance Redressal
In respect of the Personal Information or Sensitive Personal Data or Information which you have provided to us (“Collected Information”), should you wish to (i) request deletion of the Collected Information you have provided to us, from our records, (ii) correct or update the Collected Information, (iii) raise any queries or concerns regarding the purpose of retention, end-use(s) of the Collected Information, or (iv) report a breach of this Privacy Policy, please contact our grievance officer, Ankur Lahoti (“Grievance Officer”) at ia_compliance_officer@wealthbeacon.ai. Our Grievance Officer is accessible between 9 AM to 6 PM on weekdays (except public holidays) and will address your queries or grievances within one month from the date of receipt of such queries or grievances. To the extent you are exercising any of your rights under applicable law, we will respond as soon as possible, and in any event within 30 days or in accordance with the timeframe permitted under applicable law. You have the right to file a complaint with the Data Protection Authority once constituted, against the refusal to hear a complaint or dissatisfaction in the manner in which the complaint was resolved. We may seek certain information from you (such as your name and registered contact number or email address) during the grievance redressal or feedback process in order to verify your identity and establish secure modes of correspondence. Kindly note that in such an event that you wish to withdraw your consent for us to collect, retain, use, or process your Collected Information, you may not be able to take full advantage of the entire scope of features and services offered to you which rely on such Collected Information, and we reserve the right not to provide such services that require the Collected Information to be supplied to us.
9. Children’s Privacy
Our Platform is not directed at anyone who we know to be under the age of 18, nor do we collect any personal information from anyone who we know to be under the age of 18. If you are under the age of 18, you should not use the Platform and should not submit any personal information to us.
10. Phishing
Safeguarding information to help protect you from identity theft is a top priority and we at Company take all measures to protect identity theft. We do not and will not, at any time, request your credit card information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
11. Links
This Platform may contain links and advertisements which may lead you to other websites, applications or platforms. Please note that once you leave our Platform you will be subjected to the privacy policy of the other Website and this Policy will no longer apply. By using this Platform, you signify your agreement to the terms of this Policy.
12. Limit of Liability
Notwithstanding anything to the contrary in this Policy or any other terms of service or use applicable as between Company and you, Company’s aggregate liability hereunder towards direct damages shall be limited to INR 1000 (Indian Rupees Thousand) only. Company’s liability shall not extend to any indirect or remote damages whatsoever, including but not limited to special, incidental, consequential, or punitive damages or loss of profits.
13. Contact Us
If You believe that Company has not complied with this Policy with respect to your personal information or would like us to update information, we have about you or your preferences or if you have any questions about our Policy, please feel free to contact our Privacy Grievance Officer at:
Name: Ankur Lahoti
Email ID: ia_complaints@wealthbeacon.ai, ia_principal@wealthbeacon.ai
14. Applicability of Policy
While this Policy applies to all personal information collected, stored and used by Company, it is intended to comply only with the applicable laws of India. All matters of dispute are subject only to the courts in the city of Bengaluru, India.
15. Compliance
Company shall always cooperate with regulatory authorities and investigating agencies in India in the matter of treatment of personal information.
16. Severability
In the event that any part of this Agreement shall be held by a court of competent jurisdiction to be unlawful or otherwise unenforceable, the remainder of this Agreement shall remain in full force and effect to the maximum extent possible, and an attempt shall be made to substitute the unenforceable provision with an enforceable provision of similar intent.
17. Assignment
Company may, at any time, assign this Agreement and/or its rights and obligations under this Agreement to any entity, in its sole discretion.
18. Updates
From time to time, we may update this Privacy Policy. Any changes will become effective when we post the revised Privacy Policy on the Platform. Your continued use of the Platform following these changes means that you accept the revised Privacy Policy, as amended. You are encouraged to review this Privacy Policy from time to time. Company may modify this Policy in its sole discretion at any time. While Company shall make best efforts to notify You of any such modification, it shall be Your responsibility to read and understand the Policy as prevalent from time to time. Continued use of the Platform shall be deemed to constitute acceptance of the Policy as amended.