Privacy Policy
I. Policy & Purpose
This privacy policy (“Privacy Policy”) adopted by Independent Advisors Private Limited (hereinafter referred to as “We” / “Our” / “Us” / “the Company”) 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, or Our website (https://www.valueresearchstocks.com/) (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 Information” or “Sensitive Information” means Personal Information, that consists of the (i) password, (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 (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and the Personal Data Protection Bill.
II. Our Business & Policy Applicability
The Company is engaged in the business of providing research-based recommendations on various investment opportunities in equities for the long-term through the Platform. By visiting the Platform, merchants, and customers (hereinafter referred to as “Users” “You” “Your”) can access Our services, which include the provision of an interface that integrates third-party stockbroking services, such as stock recommendations, stock screener tool and stock transactions through third party application program interfaces.
By accessing the Platform, You 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 collected from You, as set out herein below.
This Privacy Policy does not apply to mobile applications or websites which are not owned or controlled by the Company, 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.
III. Collection & Use of Information
A. Personal Information Collected
When You access the Platform for certain activities or to avail Our services, we may ask You to provide Personal Information about yourself, such as:
Data Collected | Purpose |
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Name | Creation of account and to personalise communications to you |
Email Address | Creation of account/ verification of identity and to send updates and communication we think is relevant to you |
Phone Number | Verification of identity & delivery of alerts and updates |
Address | Generation of invoice, delivery of physical copies of magazines, books, newsletters and mailers |
While most information we collect can be shared at the discretion of the Users, some Personal Information (an indicative list of which is set out above) 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 the Company to provide you with a specific service or feature, You will not be able to access such service or feature of the Platform.
B. User Supplied Data
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 the Company, We may also use Your contact information for delivery of recommendations and other services subscribed by You from the Platform. You may opt out of receiving any non-essential communications from us by contacting Our Grievance Officer (defined below).
C. Sensitive Personal Data or Information Collected
Please note that 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 over secure sites that are digitally encrypted, and provide the highest possible degree of care available under the technology presently in use. The Company 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 may from time to time choose to provide details of the securities owned by You, the number of securities held and details of your broker which is classified as Sensitive Personal Data or Information. Such 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 (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.
D. Non-Personal / Aggregated Data
Apart from the information You provide to us, we may also collect information related to Your browser, internet protocol address, and browser history when using the Platform. 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.
IV. Storage & Security
All information provided by You is stored and retained on secure servers located in Noida, India. The Company 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 Practice involves 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. The Company’s Security Practice protects against unauthorized access to, or unauthorized alteration, disclosure or destruction of the information. The Company’s Security Practices contains are commensurate with the information assets being protected and with the nature of the business. By using the Platform, you accept that the Security Practice and procedures mentioned above, which are designed to protect the information provided by You, are reasonable.
The Company 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.
V. Data Transfers & Disclosures
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:
i. Provision of Services:Where any service requested by You involves a third party, such information, as is reasonably necessary for the Company 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 credit 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 |
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Value Research India Private Limited | To enable Users to avail services of Value Research Online using a single log-in. |