Privacy Policy - SALT

Privacy Policy

Last Updated: 23 June 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, use and disclose the information received through the Website, app or any other methods whatsoever.

By accessing or using the website, user unconditionally accepts and agrees without limitation or qualification to the terms and conditions of this policy. if you do not agree with the terms and conditions of this policy, please do not proceed or continue further to use this website.

DEFINITIONS

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

“Use” or “Using” means to browse, access, view, copy, availing Services or other benefit from using the Website;

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

“KYC” means know your client.

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

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

“Website” or “SALT Websites” 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 Website 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.

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

Seven Salts Financial Services Private Limited (“Seven Salts”), having its registered office at 40, Renaissance HVV, Jalahalli, Bengaluru, Karnataka 560015, India, is a company registered with the Securities and Exchange Board of India (SEBI) as a Stock Broker under SEBI (Stock-brokers and Sub-brokers) Regulations 1992 vide registration no. INZ000303532. The Mutual Fund products that you will purchase and sell using the Platform would be facilitated by Seven Salts Financial Services Private Limited, a wholly owned subsidiary of Five Salts Private Limited.

The group, affiliate and subsidiary companies of SALT shall include Five Salts Private Limited, Seven Salts Financial Services Private Limited, Nine Salts Pte Ltd. among others.

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

PERSONAL INFORMATION

In order to avail the Services offered by or on the Website and start investing, Users may be required to login/register and provide information and data (‘Personal Information’) 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 (“SPDI Rules”). Personal Information provided in acceptance of this Policy shall amount to written 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 your name, gender, age marital status permanent and current 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.

The below are the Services currently being provided or which may be provided in the future by the Platform (“Platform Services”):

  1. Maintaining a record of your personal information and financial information in a secure and confidential manner. SALT may share your KYC and other related data with its group, affiliates, and subsidiary companies as required
  2. Tracking money flows of the user
  3. Facilitating purchase and sale of Mutual Funds
  4. Facilitating purchase and sale of Digital Gold
  5. Enabling you to earn and redeem Digital Gold rewards

Once you decide to purchase Mutual Funds, you may have to complete the KYC process as required in accordance with the applicable laws and the guidelines issued by the regulatory / government agencies or authorities from time to time. . These may include the above registration details as well as PAN card details, photo, bank account details, address proof, Aadhar/passport details, cancelled cheque and virtual signature. These information and documents may be accessible by third-party vendors with whom SALT, its group, affiliate or subsidiary companies may have an arrangement with for performing KYC services, to the extent required for performing such services. SALT, its group, affiliate or subsidiary companies and/or the third-party vendors will preserve 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, its group, affiliate or subsidiary 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. In addition, SALT will store information relating to purchases made on our platform for the purpose of showing your dashboard. This information will not be shared with any third party.

While we shall make best effort to help you complete your transaction, SALT shall not be responsible, in the event, any discrepancy is found, in any of the information provided by the User, such as mismatch of the information provided, which shall lead to the rejection of account opening.

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 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. 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.

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

As SALT has tie-up(s) with external payment gateways, for Electronic Payment Gateway facility, only internet banking and UPI facility shall be offered for transaction on the Website, through a third party net banking service provider registered with the Reserve Bank of India. SALT shall not collect your credit card number, CVV number, and expiration date, for any transactions on the Website.

You have right(s) not to provide any Personal Information on the Website or any third-party website(s). 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, as requested in the process. 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 as provided on the Website.

We may also collect certain non-personal information, 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 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.

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, User can change through entering the Website with its “Login Credentials” and make changes as required. 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 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 its consent given earlier for providing Personal Information, the User shall send in request for such withdrawal to SALT in writing. In the event of such withdrawal request, SALT shall have the option to not provide the 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, change your password and contact us immediately for further assistance, on the following e-mail: connect@salt.one

USE OF INFORMATION

SALT uses the 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 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, its group, affiliate and subsidiary 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.

You also specifically agree and consent to SALT, its group, affiliate and subsidiary 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, 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, its group, affiliate and subsidiary companies.

DISCLOSURE AND SHARING OF PERSONAL INFORMATION

Under no circumstances, SALT will 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 Website information to reputable third-party vendors, but these statistics will, in no way, include any personally identifying information of our Users.

All employees of SALT have been selected in accordance with our strict security policies and practices and are 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 couriering documents to you on our behalf or operating the payment gateway functionality of the website. Such third parties are required to maintain the confidentiality of the information we provide to them under contract and under law.

We may share Personal Information, without obtaining prior consent from the User, with government agencies mandated under law to obtain information including Sensitive Personal 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 to disclose your Personal Information in such cases. Notwithstanding anything contained in this Policy, any Sensitive Personal 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 adheres, to whom the transfer of data takes place, adheres to the same level of data protection as mandated under the SPDI Rules

SALT, its group, affiliate and subsidiary 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 our website.

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 although it will enable the Website to relate your use of the Website to information that you have specifically and knowingly provided to the Website. 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 website.

LINKS TO THIRD PARTY SITES

We may provide links of other websites of interest on the Website, 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 the Website. 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 Website 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.

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, content, photographs, images, experience sharing, feedback, opinions that is voluntarily shared by you with us or uploaded on the Website 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, only on our Website.

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, its group, affiliate or subsidiary 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.

CHANGES TO PRIVACY POLICY

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

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 Website and supersedes any and all prior understandings relating to the Website. 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 Website.

LEGAL OBLIGATION

SALT is bound by the Information Technology Act, 2000, 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 & conditions for access or usage of the Website.

In accordance with Regulation 4 of the SPDI Rules, SALT is obliged to provide every registered user of the Website 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 our Grievance Officer at connect@salt.one