Privacy Policy - SALT

Privacy Policy - TLDR

We encourage you to read the detailed Privacy Policy, but we surely recommend that you read the following summary:

On the SALT platform, we offer products and services created by us (Five Salts Private Limited) as well as our partners, including Seven Salts Financial Services Private Limited, our group company that is a SEBI registered Stock Broker. We are sensitive to your concerns on data security, confidentiality and privacy. We are committed to keeping the SALT Platform safe and your information confidential, as well as meeting regulatory requirements of KYC and responsible selling of financial products. This means for you-

  1. To enter your login credentials and create an account for SALT Platform, you may be asked for your Personal Information such as name, gender, age, marital status, permanent and current address, email address, income group, and contact number (verified using OTP). We use this information to identify you and ensure that genuine users use the SALT Platform. We do not share this data with third party(ies) except partners on our SALT Platform, in accordance with the applicable laws, whose services you opt to use.
  2. For conducting KYC for regulated financial products, SALT shall use the above registration details and ask for additional information (to the extent required) including but not limited to PAN card details, photographs, bank account details, IFSC, FATCA and annual income declarations, nominee details, marital status, address proof, Aadhaar/passport details, cancelled cheque and virtual signature.
  3. The partners with whom SALT and/or its group companies has entered into arrangements for KYC are bound by contract and shall access the information only to the extent required for performing the services. SALT shall preserve a record of the information shared by you for such period as required under applicable laws.
  4. In case you want to access or update any earlier provided information, you can write to SALT at connect@salt.one. Some changes may need documentary evidence, if required. This is to ensure that your data remains safe.
  5. To operate the SALT Platform securely, we may also collect certain non-personal information, if required, such as your internet protocol (IP) address, web request, operating system, browser type, URL, internet service provider, aggregate user data, browser type, software and hardware attributes, pages you request, and cookie information etc. which will not identify with you specifically while you browse, access or use the SALT Platform.
  6. SALT uses the Personal Information and Sensitive Personal Information, which is received from you, to provide the services and to enhance your overall experience. SALT shall not sell, distribute, trade, lease or rent your Personal Information to anyone, for any reason(s). Also, we may provide aggregate statistics about our customers, sales, traffic patterns, and related information from SALT Platform to reputable third-party vendors, but these statistics will, in no way, include any of your personally identifiable information.
  7. If you post messages on our message boards, chat rooms or other message areas or leave feedback, SALT will collect and store such information. Your telephonic conversation with the customer support department of SALT (managed by itself or through any outsourced vendor) will also be recorded for quality control, record retention purposes, and other similar purposes.
  8. When you access your account information, SALT offers the use of a secure server. The secure server software (SSL) encrypts all information you input before it is sent to SALT. Your password information is not accessible to anyone including SALT.
  9. In case you want to delete your Account on SALT Platform, you may write to connect@salt.one. Upon receipt of such request, SALT shall have the right but not the obligation to delete your Account. In case SALT confirms your Account deletion request, SALT may de-activate your Account and you shall no longer have access to the Services provided on SALT Platform. However, SALT shall continue to maintain a record or a copy of certain requisite information for regulatory purposes.

Privacy Policy

Last Updated: 5th October 2022

Welcome to app.salt.one and the SALT mobile app operated and owned by Five Salts Private Limited (“Company” or “SALT”). We value our customers and we are committed to ensures privacy and confidentiality, integrity and security of our Users” and their personal information, at all times. This privacy policy (“Policy”) is to familiarize the Users with the manner in which we collect, store, use and disclose the information received through the Platform or any other methods whatsoever.

This Policy specifies the manner in which personal data and other information is collected, stored, processed, transferred, disclosed, dealt with, or otherwise handled by the Company or any of its Group Companies.

By accessing or using the SALT Platform, You unconditionally accept and agree (without limitation or qualification) to the terms and conditions of this policy. If you do not agree to the terms and conditions of this policy, please do not proceed or continue further use of this Platform.

DEFINITIONS

“Customer” means User who has or is willing to obtain the Services of SALT Platform.

“Group Companies” means and includes SALT, Seven Salts Financial Services Private Limited, Nine Salts Pte Ltd., among others.

“KYC” means know your customer / client.

“Login Credentials” mean a User”s email address / contact number and password determined by such User.

“Registered User” or “Registered Customer” shall mean and include the Users or Customers who access services of SALT platform (“SALT Platform” or “Platform”), to browse or avail the Services or any part thereof, as provided on the SALT Platform.

“Services” means all the services as provided in Terms & Conditions from time to time.

“User/user”, “You/you”, “Your/your” means any person, user, Registered User, viewer or Registered Customer who views, browses, accesses or uses our Platform.

“Use” or “Using” means to browse, access, view, copy, availing Services or other benefit from using the SALT Platform.

“SALT” or “us” or “we” or “our” shall mean and refer to Five Salts Private Limited, officers, employees, agents, partners and licensors.

“Terms & Conditions” shall mean the terms of use of the SALT Platform, including any amendment or re-enactment thereof.

“SALT Platform” / “Platform” means and includes www.salt.one and app.salt.one, SALT mobile application accessed through or downloaded from the app store i.e. Android or IOS, which might be used or accessed at any other platform where the SALT Platform can be accessed from on mobile phones and such other devices, like, mobile application (whether or not on android or IOS) or any other platform as provided by SALT.

PERSONAL INFORMATION

In order to avail the Services offered by or on the SALT Platform and start investing, Users may be required to login/register and provide information and data (“Personal Information”). In addition, they may also provide some other information that may be classified as “Sensitive Personal Information” under Regulation 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“Sensitive Information”). Personal Information and Sensitive Information provided in acceptance of this Policy shall amount to Your written affirmative consent under Regulation 5 of the SPDI Rules

Since SALT is a platform that provides customers access to curated services of verified partners, our initial registration process is designed to collect minimum information that is required to ensure login credentials of users. At this stage, this may include but not limited to your name, gender, age, marital status, permanent and current address, email address, income group, and contact number (verified using OTP). This initial registration is to enable users to create a username and password. It is our commitment to protect this information and share it with partners whose services you opt to avail, using secured channels and in compliance with regulations governing the concerned partners and services offered by them

SALT shall further request your consent to track your activity across other apps on your device. SALT shall also be placing a third-party SDK in the mobile app that combines your data from the mobile app with your data from other developers' apps to target advertising or measure advertising efficiency. For example, using a login SDK that repurposes the data SALT collects from the mobile app to enable targeted advertising in other developers' apps. SALT shall also request access to the advertising identifier (IDFA), to collect Device IDs and use them for tracking purposes.

You may have to complete the KYC process as required by SALT for various services offered by SALT on its Platform, in accordance with the applicable laws and the guidelines issued by the regulatory / government agencies or authorities from time to time. The information collected may include the above registration details as well as PAN card details, photographs, bank account details, IFSC, FATCA and annual income declarations, nominee details, marital status, address proof, Aadhaar/passport details, cancelled cheque and virtual signature. Such information and documents may be accessible by third-party vendors with whom SALT, its Group Companies may have an arrangement for the performance of KYC services, to the extent required for performing such services. SALT and its Group Companies and/or the third-party vendors will preserve or process all records, documents and any other information in relation to the KYC services for the term as required under applicable law. Please note that such third-party vendors are required to maintain the confidentiality of the information we provide to them under contract and under law. SALT and its Group Companies may preserve and maintain a record of the User data collected herein for such term as required under applicable law and share the same with regulatory authorities for opening of account and completing transactions on need-to-know basis. You acknowledge and agree that SALT is not responsible for examining or evaluating the content, accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect of any third-party services. SALT does not warrant or endorse and does not assume and will not have any liability or responsibility to You or any other person for any third-party services, third party materials or web sites, or for any other materials, products, or services of third parties. In addition, SALT will store information relating to purchases made on the Platform for the purpose of showing your dashboard. This information will not be shared with any third party without User”s prior written consent.

You may, at your option, share your UPI transaction details, bank statement, merchant”s name, category and other identifiers along with the details of products or services purchased or paid for, mode of payment, location, the date, currency and amount of the transaction, whether the payment was successful, and other related information, to enable automated money flow tracking service which may be provided by SALT. We may also ask for additional Personal Information or Sensitive Information from time to time to meet new regulatory requirements or to provide you with other benefits of our services. As always, the information that we seek will only be for the purpose stated.

You provide consent for SALT to access your camera, which is required for video verification as part of Know Your Customer (KYC) for specific use cases as per Securities and Exchange Board of India (SEBI) guidelines. You further provide consent for SALT to read SMS received during authentication. You are only granting permission for SALT to read SMSes shared by SALT and/or its Group Companies.

In order to provide you a better experience and service and information about your investments/products, SALT will access information relating to your investment/other purchases made on the Platform from the partners/service providers. Based on such information, SALT would build data such as Your intent to invest, Your portfolio.

We will use this information to contact you and undertake activities that you query or authorize us to do.

SALT partners with external payment gateways to provide electronic payment gateway facility to Users for the transactions initiated by the Users on the Platform.

You are entitled to choose to not provide any Personal Information or Sensitive Information on the SALT Platform or any third-party website(s) to which you are directed from the SALT Platform. It is not mandatory to provide your Personal Information, however, we will be able to provide you the Services only when You disclose certain Personal Information and Sensitive Information, as requested as a part of, and required to avail the Services. If you intend to use the Services, it is solely at your own volition, risk and after reading and confirming this Policy in conjunction with other policies, including but not limited to terms of service, addendums to mutual fund and digital gold, as provided on the SALT Platform.

In case you want to delete your Account on SALT Platform, you may write to connect@salt.one. Upon receipt of such request, SALT shall have the right but not the obligation to delete your Account. In case SALT confirms your Account deletion request, SALT may de-activate your Account and you shall no longer have access to the Services provided on SALT Platform. However, SALT shall continue to maintain a record or a copy of certain requisite information for regulatory purposes.

NON-PERSONAL INFORMATION

We may also collect certain non-personal information, if required, such as your internet protocol (IP) address, web request, operating system, browser type, URL, internet service provider, aggregate user data, browser type, software and hardware attributes, pages you request, and cookie information etc. which will not identify with you specifically ("Non-Personal Information"), while you browse, access or use the Platform. We receive and store Non-Personal Information, by the use of Cookies on certain pages of the Platform, in order to help and analyze our web-page flow, track user trends, measure promotional effectiveness, and promote trust and safety.

Any personally identifiable information provided by you will not be considered as Sensitive Information if it is freely available and / or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, twitter etc. Further, any posted/uploaded/conveyed/communicated by users on the public sections of the Sites becomes published content and is not considered personally identifiable information subject to this Privacy Policy.

In addition to the above, we identify and use your IP address to help diagnose problems with our server, resolve such problems and administer the Platform. Your IP address is also used to help identify you and to gather broad demographic information.

STORAGE OF USER”S INFORMATION

If you choose to post messages on our message boards, chat rooms or other message areas or leave feedback, we will collect and store such information you provide to us. We retain this information as necessary to resolve disputes, provide customer support, respond to queries and inquires, and troubleshoot problems and improve the Services.

If you send us correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Platform, we may collect and retain such information into a file specific to you for responding to your request and addressing concerns in relation to your use of the Platform. We shall be entitled to retain your Personal Information and other information for such duration as may be required for the purposes specified hereunder and will be used by us only in accordance with this Privacy Policy.

SALT may use the information we collected online in conjunction with the personal information you have provided us with, or information that is publicly available from other sources. SALT may use this information to customize your experience and our communication with you both online and offline.

ACCESS AND UPDATE YOUR PERSONAL INFORMATION

Personal Information provided by the User belongs to the User. In the event, User wants to access or update any earlier provided information, the User can write to SALT atmailto:connect@salt.one. Some of the changes made or proposed by the User may require User to provide documentary evidence. In any event, upon your written request, SALT has a legal obligation and will provide every User a readable copy of the personal data that we keep or maintain about You. As an added security measure and regulatory requirements, we may require additional proof of identity prior to such disclosure.

If the User wants to withdraw his consent given earlier for providing Personal Information, the User shall send in request for such withdrawal to SALT in writing. Withdrawing User”s consent shall not affect the lawfulness of any processing we conducted prior to your withdrawal, as may be necessary. It will not affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. In the event a User chooses to withdraw your consent for collecting and processing your personal data, we will be unable to provide User with our products and services.

Remember to keep your Login Credentials safe and secret to prevent unauthorized access to your SALT account. If you think that the security of your SALT account has been compromised, you are advised to change your password and contact us immediately for further assistance, on the following e-mail connect@salt.one

In case of customer support, we will be recording Your telephonic conversation with the customer support department of SALT (managed by itself or through any outsourced vendor) for quality control, record retention purposes, and other similar purposes.

USE OF INFORMATION

SALT uses the Personal Information and Sensitive Personal Information, which is received from Users to provide the Services and to enhance the overall experience of its users. Access to the Login Credentials, Registration Information, and any other Personal Information as provided by the users is restricted and used in accordance with specific internal procedures in order to operate, develop or improve our Services.

SALT uses the Personal Information, Sensitive Information and other Non-Personal Information, for the following: (i) to provide and improve the Services on the Platform that you request; (ii) to resolve disputes and troubleshoot problems; (iii) to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users; (iv) collect money from you in relation to the Services, (v) inform you about online and offline offers, products, services, and updates; (vi) customize your experience on the Platform or share marketing material with you; (vii) to detect, prevent and protect us from any errors, fraud and other criminal or prohibited activity on the Platform; (viii) enforce and inform about our terms and conditions; (ix) to process and fulfil your request for Services or respond to your comments, and queries on the Platform; (x) to contact you; (xi) to allow our business partners and/or associates to present customized messages to you; (xii) to communicate important notices or changes in the Services provided by the Platform, use of the Platform and the terms/policies which govern the relationship between you and SALT and its Group Companies as set out in “Disclosure and Sharing of Personal Information” for providing services to you; and (xiii) for any other purpose after obtaining your consent at the time of collection.

In the course of availing SALT”s Services, You also specifically agree and consent to SALT and its Group Companies collecting, storing, processing, transferring and sharing information (including Personal Information) related to you with third parties such as Banks, financial institutions, credit information companies, payment facilitators, entities registered under applicable laws with Securities Exchange Board of India, National Stock Exchange of India Limited/BSE Limited/payment gateways/ collecting banks/KRAs etc. solely for the purpose of reviewing your profile and processing your transaction requests for the Services or for such other products/services offered by SALT and its Group Companies.

DISCLOSURE AND SHARING OF PERSONAL INFORMATION

Under no circumstances will SALT sell, distribute, trade, lease or rent the Personal Information of its Users to anyone, for any reason(s). Also, we may provide aggregate statistics about our customers, sales, traffic patterns, and related information from SALT Platform to reputable third-party vendors, but these statistics will, in no way, include any personally identifiable information of our Users. You hereby accord your consent for such use of your data.

All employees of SALT have been selected in accordance with our strict security policies and practices and are contractually bound by confidentiality obligations. SALT employees are subject to stern disciplinary action, including termination, civil liability, and criminal prosecution, if they fail to meet any of these obligations, as stated.

SALT may also use third party vendors or service providers to help us provide services to you, such as emailing, couriering documents to you on our behalf or operating the payment gateway functionality of the Platform. Such third parties are required to maintain the confidentiality of the information we provide to them under contract and under law. The information that we provide to any third-party would be on a need-to-know-basis.

We may share Personal Information, without obtaining prior consent from the User, with government agencies only if mandated under law to obtain information including Sensitive Information or Personal Information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences, or to protect the interests of SALT and/or any particular user(s). You authorize us and agree to disclose your Personal Information and Sensitive Information in such cases. Notwithstanding anything contained in this Policy, any Sensitive Information or Personal Information shall be disclosed to any third party by an order under the law for the time being in force.

SALT may transfer Personal Information, to any other body corporate or a person, provided that such transfer is necessary for the performance of a lawful contract between SALT and the User or where the User has consented to such transfer.

Further, SALT shall ensure that such body corporate or person, to whom the transfer of data takes place, adheres to the same level of data protection as mandated under the SPDI Rules

SALT and its Group Companies may, in compliance with applicable laws, share/transfer/assign all of your Personal Information and other information with any other business entity(ies), in the event of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of the business.

COOKIES

“Cookies” are small files or small pieces of information that are stored by your browser on your computer”s hard drive. Most web browsers automatically accept Cookies, but you can usually change your browser to prevent that. Even without a Cookie, you can still use most of the features at the SALT Platform.

Cookies allow web and mobile applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log Cookies to identify which pages are being used. We may place Cookies in the browser files of Your computer/mobile phone. The Cookie itself does not contain Personal Information or Sensitive Information although it will enable the SALT Platform to relate your use of the Platform to information that you have specifically and knowingly provided to the Platform. The Cookies enable us to remember your choices and some data field contents which you would be required to fill-in. This may reduce your time to fill in information which is routine or repetitive in nature. Such information will also remain in our database.

You can choose to accept or decline Cookies. Most web and mobile browsers automatically accept Cookies, but you can usually modify your browser setting to decline Cookies if you prefer. This may prevent you from taking full advantage of the Platform.

LINKS TO THIRD PARTY SITES

We may provide links of other third-party websites of interest on the SALT Platform, without any accuracy, completeness, or usefulness of any content, warranty, merchantability, endorsement, suitability, any assurance of quality, authenticity, and appropriateness to view such websites and responsibility, liability, obligations on part of SALT and/or its Group Companies. This Policy does not apply when you access such sites or links.

These third-party websites may use technology to send the advertisements that appear on the Platform directly to User. SALT does not have access to or control over the Cookies or other features that such third-party websites may use, and the information practices of these third-party websites are not covered by this Policy. Therefore, SALT cannot be held responsible for the protection and privacy of any information which User provides whilst visiting such websites of interest. Users shall contact them directly for more information about their privacy practices.

Any opinions, advice, statements, services, offers, or other information or content expressed or made available by third parties, including information providers, or any other Users are those of the respective author(s) or distributors and not of the SALT.

PROTECTION OF INFORMATION AND STORAGE

When any user accesses its account information, we offer the use of a secure server. The secure server software (SSL) encrypts all information you input before it is sent to us. Furthermore, all of the Customer data we collect is protected against unauthorized access.

Every time you login using your Login Credentials, we use, inter alia, the latest authentication and encryption protocols along with firewalls and session time outs to protect your account from unauthorised access. Your password information is not accessible to anyone including us.

We also need to make you aware that although we provide appropriate firewalls and protections, our systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible and Company takes no liabilities or responsibilities for it.

You agree that, all intellectual property including but not limited to copy right, trade mark, any Personal Information, Sensitive Information, content, photographs, images, experience sharing, feedback, opinions that is voluntarily shared by you with us or uploaded on the SALT Platform do not infringe any rights of third parties in any manner and you give us unrestricted, perpetual right of use of such intellectual property for any purpose whatsoever.

We work to protect the security of your information as per the International Standard IS/ISO/IEC 27001 on “Information Technology Security Techniques Information Security Management System-Requirements”.

SALT shall, at all times, take all the reasonable precautionary measures to safeguard the information provided by users on our Platform.

We shall retain the records as per applicable laws and such other statutory / regulatory requirements from time to time. In the event any legal / regulatory proceeding is pending, we can retain records for a longer period. We shall store the data/ information/ records on a server owned by SALT and its Group Companies in India.

We may keep our records of the electronic instructions/transactions in any form as permitted under Applicable law. In this regard, all records, whether in electronic form, magnetic form, documents or any other form with respect to electronic instructions/ online transactions shall be conclusive evidence of such instructions/ transactions and shall be binding on the User.

CONSENT AND CHANGES TO PRIVACY POLICY

When a User creates a login ID and password or sign-in to the SALT Platform, User is providing consent to this Policy.

SALT has and continues to have the right to unconditionally modify, change or update this Policy at any time by reasonably highlighting on the SALT Platform any such change. Such changes shall be effective immediately upon posting on the SALT Platform. You are advised to keep a regular check and update yourself on the policy updates on the Platform.

The date of last revision appears at the top in ‘Last Updated’ and all changes take effect immediately upon posting.

AGREEMENT

This Policy along with the Terms & Conditions and any other relevant policies or disclosures contains the entire understanding and agreement between the User and the SALT Platform and supersedes any and all prior understandings relating to the SALT Platform. This Policy cannot be changed or terminated orally. If any provision of this Policy is held to be illegal, invalid or unenforceable, this will not affect any other provisions and the Policy will be deemed amended to the extent necessary. Any provision which must survive in order to allow us to enforce its meaning, shall survive the termination of this Policy. This Policy should at all times be read along with the Terms & Conditions and any other policies of the SALT Platform.

LEGAL OBLIGATION

SALT is bound by the Information Technology Act, 2000, and the rules thereunder and complies with all its provisions. In accordance with the Section 43A of Information Technology Act, 2000 read with Rule 8 of the SDPI Rules, SALT is obliged to maintain reasonable security procedures to safeguard the user data received or provided by the User.

This document is published in accordance with the provisions of Rule 3 (1) of the Information Technology (Intermediaries guidelines) Rules, 2011 and Rule 4 of the SPDI Rules of the that require publishing the rules and regulations, privacy policy and terms of use for access or usage of the SALT Platform.

In accordance with Regulation 4 of the SPDI Rules, SALT is obliged to provide every registered user of the SALT Platform with a readable copy of the information that it keeps about you. If the user would like to have a copy of the same, user can reach out to SALT at connect@salt.one

CONTACTING US

For questions related to updating or changing your account information or any other Information provided by you and for Your valuable feedback regarding this Policy, please send an e-mail to connect@salt.one

Further, for time-bound and speedy redressal of any discrepancies and grievances in relation to Personal Information provided, please feel free to reach out to Aditi Sholapurkar, our Grievance Officer at 9108699588 and email at connect@salt.one