Mintd Investment Advisers Private Limited (“Mintd”) is a private limited company incorporated under the Companies Act, 2013 (CIN U67190MH2021PTC368590), having its registered office at 501-A Pinnacle Corporate Park Vill Kole Kalyan, Nr. Trade Center, BKC Bandra (E), Mumbai – 400051, Maharashtra, India. Mintd, through its affiliate KIA Financial Services (Mutual Fund Distributor, ARN - 104672), offers a digital platform to investment in mutual fund portfolios. The services are offered via our website www.mintd.in (“Mintd”) and/or mobile applications, herein after collectively referred to as the “Platform”,
- What information do we collect?
We collect Personal Information and Non-Personal Information (as defined below) from you when you register or set up account with us on our Platform. When you start using the Services, we ask you to provide certain information as part of the registration process, and in the course of your interface with the Platform. We will collect this information through multiple means and in various places through the Services, including but not limited to, account registration forms, contact us forms, or when you otherwise interact with Mintd, including at customer support.
- Information that you may provide to us voluntarily while registering on our Platform for using our Services, including but not limited to, full name, mobile number, email address, password, photograph, audio file, location, date of birth, gender, Permanent Account Number (PAN), Aadhaar details, e-KYC through UIDAI, CKYC through CERSAI, income/salary information, marital status, sexual orientation, biometric data, health status and nominee details. To complete your profile assessment we may ask you questions related to your risk appetite for investments and investment goals. We may also ask you to provide your financial information including but not limited to, billing address, bank account details, credit/debit card details, payment related details, payment method data, debit instructions, e-mandates, standing instructions or any other personal/financial information as required by various applicable laws and regulations from time to time to process the Services (“Personal Information”).
- Certain additional information about yourself on a case to case basis. When you visit our Platform, we may log certain non-personal information such as your IP address, cookie information, browser type, mobile operating system, manufacturer and model of your mobile device, geolocation, preferred language, access time and time spent. We will also collect information about the pages you view within our sites and other actions you take while using the Platform (“Non-Personal Information”). We receive and store Non-Personal Information, by the use of the data collection devices such as ‘cookies’ on certain pages of the Platform, in order to help and analyse our webpage flow, track user trends, measure promotional effectiveness, demographic studies and promote trust and safety. This Non-Personal Information is compiled and analysed by the Company on an aggregated basis and not individually, in a manner that does not specifically identify you.
- Any information that is freely available, accessible in the public domain, furnished under the Right to Information Act, 2005 or any other law for the time being in forced, where such information shall not be regarded as sensitive personal data or information. We may also retrieve from your records available with third party Know Your Customer (KYC) Registration Agency (KRA), information such as your KYC details, KYC status, father’s name, occupation, address details and related documents.
- All such Personal Information and Non-Personal Information described above, which shall be deemed to be disclosed willingly and without any coercion. No liability of any form pertaining to the authenticity/genuineness/misrepresentation/fraud/negligence, etc. of the Personal Information provided by you, shall lie on the Company, nor will the Company be in any way responsible to verify any information obtained from you. The sole liability for any misrepresentation/fraud/negligence/ any other criminal or civil liability emanating from the information provided by you shall be your responsibility.
- The Company’s use of information received from Google APIs will adhere to The Company’s use of information received from Google APIs will adhere to Google API Services User Data Policy , including the Limited Use requirements.
We take care to allow your Personal Information and Non-Personal Information to be accessed only by those who really need it in order to perform their tasks and duties and to third parties who have a legitimate purpose for accessing it and with your consent. Your Personal Information and Non-Personal Information will be transferred only to a Third-Party Sites that ensures the same level of data protection that is mandated under the IT Act and the SDPI Rules.
- Links to third party sites
- How do we use your information?
We use the Personal Information and Non-Personal Information provided by you:
- To create your account, verify your identity, and process your transaction(s) on the Platform;
- To provide you services on the Platform;
- To collect statistics about your usage of the Platform and its effectiveness;
- To improve and personalize your experience of the Services, as well as customize our interactions with you to further expand the scope of the Platform;
- To resolve disputes, provide customer support and troubleshoot problems that arise from using our Platform;
- To help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users;
- To inform you about online and offline offers, campaigns, programs, products, services and/or updates;
- To customize your experience on the Platform or share custom marketing material with you;
- To detect, prevent and protect the Company from any errors, frauds, and other criminal or prohibited activity on the Platform;
- To enforce and inform you about our Terms of Service;
- To process and fulfil your request for Services or respond to your queries on the Platform;
- To contact you;
- To allow our business partners and/or affiliated entities to present customized messages to you;
- To communicate important notices or changes in the Services offered by the Company, use of the Platform, and the terms/policies which govern the relationship between you and the Company and with our affiliates; and
- For any other purpose, for which you have granted access to such information to us, based on your interaction with Platform.
We may send you text messages on your registered mobile number that you share with us. All text messages originating from us, where applicable, through our authorized third-party service providers will at all times be compliant with guidelines prescribed by the Telecom Regulatory Authority of India (“TRAI”). The nature of communication from us is broadly classified into two (2) categories:
- Transactional SMS. Transactional messages are messages that carry your account and transaction specific information such as one-time passwords (OTP) in connection with registration for any of the Services or campaign related offerings, account status, invoice details, confirmation alerts, bank accounts status and other details in the form of real-time updates on the activities on your account. You may receive Transactional SMS even if you are a Do-Not-Disturb (“DND”) registered user.
- Promotional SMS. You may also receive text messages in the event that you are a non-DND registered user. We may send you such text messages to update you on our service offerings that may be of interest for you.
You specifically agree and consent to us collecting, storing, processing, transferring and sharing your Personal Information and Non-Personal Information for the aforementioned use-case.
- Disclosure of information?
We may disclose your Personal Information and Non-Personal Information, to the extent necessary:
- To statutory and regulatory authorities to comply with applicable laws and to respond to lawful requests and due legal process;
- To protect the rights, property and safety of the Company, our business and services partners and the users, including to enforce the Terms of Service;
- To our subsidiaries and affiliates, in the ordinary course of business;
- To third-party websites;
- To third-party service partners, including business partners, affiliates, service providers, entities registered under applicable laws with Securities Exchange Board of India (SEBI), National Stock Exchange of India Limited, Bombay Stock Exchange Limited, authorized payment gateways, collecting banks, KRAs, credit bureaus, etc. for the purpose of billing and collection, providing content, products, customer support etc.;
- In case of a corporate sale, merger, acquisition, sale of business, reorganization, dissolution, insolvency or such similar events;
- To third parties to market their products/services/campaigns/programs, subject to whether users have either consented or not opted out of these disclosures;
- To fulfil the purpose for which the user provided such information;
- For any other purpose for which the User provided it;
- How do we retain your information?
We may store and retain your Personal Information and Non-Personal Information, to the extent necessary:
- To carry out the Services for the user on the Platform. Generally, this means, we will keep your Personal Information and Non-Personal Information as long as your account is active or as needed to provide our Services;
- Retain and use the information collected as necessary to comply with our legal obligations, resolve disputes or for other business purposes;
- Retain your Personal Information and Non-Personal Information for  months after you cancel/ deactivate/ unsubscribe your account with us, as our business practice; and
- Where we have no continuing legitimate business need to process your Personal Information and Non-Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
- How is your information transmitted and stored?
Your information including Personal Information is transmitted between your device and our servers using HTTPS protocol for encryption. HTTPS is the technology used to create secure connections for your web browser and is indicated by a padlock icon in your browser. In addition to HTTPS, we make sure that your Personal Information is always encrypted or hashed before we store it. We use industry standard encryption and hashing algorithms.
- How do we protect information we collect?
We are dedicated to guarding the security of your information and our Platform has several industry-standard security technologies and procedures devised to help protect your data from unauthorized access, use, destruction or disclosure, including technical and organizational security measures to protect the security of your personal data both online and offline. The App receives regular security scans and penetration tests. The App also receives regular malware scans. In addition, the App uses an SSL certificate as an added security measure. We require username and passwords for our employees who can access the personal information of Users that we store and/or process on the servers. In addition, we actively prevent third parties from getting access to the personal information of Users that we store and/or process on the servers. We will implement reasonable security measures every time you (a) place an order, (b) enter, submit, or access your information, (c) register, or (d) access the App.
- Data security measures
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the App and/or our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App.
In the event of a personal data breach, we will notify the User within fifteen (15) days via (i) email and/or (ii) our Platform notification system on the App. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
- How do you update your information?
You specifically consent and agree that the Personal Information pertaining to your account on the Platform shall be both accurate and current. If you wish to update your Personal Information which is inaccurate or incorrect, we shall provide self-help tools for you to directly review or update certain aspects of your Personal Information in our records. If any part of your Personal Information changes during the course of your engagement with us and your use of our Platform, please use these self-help tools provided by us to update that Personal Information.
- Consent withdrawal
If you wish to withdraw your consent given under this Policy for collection and use of any Personal Information, you can withdraw your consent by sending us an email at email@example.com
- How do you delete/deactivate your account?
Mintd does not sell, trade, or otherwise transfer to outside third parties your Personal Information as the term is defined under the SDPI Rules. Please note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our Services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. Users also have the option to request for an account deactivation instead. This will temporarily block user access to the App and the Platform until they send a re-activation request and successfully re-activate their account.
To make a request for such disclosure, or identification, deactivation and/or deletion of the Platform account and Personal Information in all our systems that we store on you, please send an email to firstname.lastname@example.org.
- Governing Law
Mintd is bound by the (Indian) Information Technology Act, 2000 and rules made thereunder, and it shall comply with all its provisions. Under Section 43A of the (Indian) Information Technology Act, 2000, Mintd and all its vendors are obliged to maintain reasonable security procedures to safeguard Your data.
Any disputes arising under this Policy shall be governed by the laws of India.
- Privacy questions and grievance redressal
In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Mr. Jaisal Mariwala