PRIVACY POLICY
Effective as of __20-07-2022
This privacy policy (this “Privacy Policy”) describes how 5paisa Trading Limited and its
affiliates (collectively, “5paisa,”,”Stocky5”, “we,” “our,” and “us”) collect, secure, use, retain,
disclose, and otherwise process your personal information when you access and use
Stocky5’s website, app and this Community Platform and when you otherwise engage with us
(for example, by contacting our customer service team) (collectively, our “Services”). This
Privacy Policy also describes the choices you can make with respect to the personal
information we collect and process about you. In this Privacy Policy, we use “customer” and
“you” to refer to anyone who accesses and uses our Services.
While operating the Website, the App, and the Community Platform, we may collect the
following types of information.
INFORMATION YOU PROVIDE TO US
When you register for the Community Platform to create an account, or contact us, you will be required to provide us with information about yourself (the “Personal Information”). Such Personal Information may include your name, address, e-mail address, phone number and other information. We may also collect information that you voluntarily provide to us, if you register for the Community Platform using your 5paisa’s trading account we may collect, store, and use any and the information provided to us through 5paisa’s trading account in accordance with the terms of its privacy policy.
INFORMATION COLLECTED AUTOMATICALLY
We may collect additional information automatically when you visit and/or use the Community
Platform including your Internet protocol (IP) address, user settings, MAC address, cookie
identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your
browser, operating system or device, location information, Internet service provider, pages that
you visit before, during and after using the Community Platform, information about the links
you click, and other information. In addition, we may collect data regarding your use of the
Community Platform, such as the types of content you interact with, information derived from
your Groups and your User Content (including other Members with whom you interact, topics
you discuss with your Groups, and anything else that you post or interact with via the
Community Platform) and the frequency, duration, and timing of your activities. We may
combine your information with information that other people provide when they use our
Community Platform.
We, as well as third parties that provide content, advertising, or other functionality on the
Community Platform, may use cookies, pixel tags, local storage, and other technologies
(“Technologies”) to automatically collect information through the Community Platform.
Technologies are essentially small data files placed on your devices that allow us and the third
parties to record certain pieces of information whenever you visit or interact with our
Community Platform. Cookies are small text files placed in web browsers to store their
preferences. Most browsers allow you to block and delete cookies. However, if you do that,
the Community Platform may not work properly. A pixel tag (also known as a web beacon) is
a piece of code embedded in the Community Platform that collects information about
engagement on a web page. The use of a pixel allows us to record, for example, that you
have visited a particular web page or clicked on a particular advertisement.
We may also use service providers to collect information regarding behaviours and demographics on the Community Platform.
HOW WE USE AND SHARE THE INFORMATION
We use the Personal Information, and Other Information (collectively, “Information”) for a variety of business purposes, including to provide you with access to the Community Platform and the services available on the Community Platform, including to:
- Fulfil our contract with you.
- Process information to facilitate your use of the Community Platform
- Manage your information.
- To send you SMS messages (if required) for purposes of authentication.
- Solicit your feedback.
- Respond to questions, comments, and other requests.
- Provide access to certain areas, functionalities, and features of the Community Platform.
- Provide you with tailored content and advertisements; and
- Answer requests for customer or technical support.
We may also use the Information to Support Administrative Purposes, including to:
- Pursue legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention.
- Measure interest and engagement in the Community Platform.
- Develop new products and services
- Improve our products and the Community Platform.
- Ensure internal quality control and safety.
- Authenticate and verify individual identity.
- Carry out audits.
- Communicate with you about activities on the Community Platform and changes to our agreements.
- Prevent and prosecute potentially prohibited or illegal activities
- Enforce our agreements; and
- Comply with our legal obligations.
Your Information is automatically made public to all Members of the Community Platform and
all Groups, Channels, or Direct Messages in which you are a member. You may adjust the
amount of Information that we share with other Members by visiting your personal privacy
settings; provided, however, that it is the purpose of this Community Platform to provide an
opportunity for Members to share their investment activity with other Members, and, therefore,
certain aspects of your Information cannot be made private.
In an ongoing effort to understand better our users and our Community Platform, we may
analyse the Information in de-identified and/or aggregate form in order to operate, maintain,
manage, and improve the Community Platform. This de-identified and/or aggregate
information does not identify you personally. We may share, sell, and/or license this deidentified and/or aggregate data with our affiliates, agents, and business partners, and other
third parties. We may also disclose aggregated user statistics in order to describe our products
and Community Platform to current and prospective business partners and to other third
parties for other lawful purposes.
We may employ other third parties such as companies and individuals providing marketing
assistance, information technology support, ID verification, purchasing and selling securities
and maintaining databases, and customer service. Our agreements with these third parties
will have access to the Information only as necessary to perform their functions and to the
extent permitted by law.
We may share your Information with any of our parent companies, subsidiaries, joint ventures,
or other companies under common control with us.
We may share Other Information about your activity on the Community Platform with third
parties for the purpose of tailoring, analysing, managing, reporting, and optimizing advertising
you see on the Community Platform and elsewhere.
Your browsing activity may be tracked across different websites and different devices or apps.
For example, we may attempt to match your browsing activity on your mobile device with your
browsing activity on your laptop. To do this our technology partners may share data, such as
your browsing patterns, geo-location and device identifiers, and will match the information of
the browser and devices that appear to be used by the same person.
As we develop our business, we might sell or buy businesses or assets. In the event of a
corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the
Information may be part of the transferred assets.
To the extent permitted by applicable law, we may also disclose the Information when required
by law, court order, or other government or law enforcement authority or regulatory agency, or
whenever we believe that disclosing such Information is necessary or advisable, for example,
to protect the rights, property, or safety of us, our users, or others.
YOUR CHOICES
You have certain choices about your Personal Information. Where you have consented to the
processing of your Personal Information, you may withdraw that consent at any time and
prevent further processing by contacting us as set forth below at the end of this policy. Even
if you opt out, we may still collect and use non-personal information regarding your activities
on the Community Platform and for other legal purposes as described above.
We will not share, disclose, or sell your Personal Information or Transactional Information with
non-affiliated third parties that may use such information to market to you, without obtaining
your opt-in consent. For example, we may offer you a product opportunity that requires us to
share your Personal Information with non-affiliated third parties that may use such information
to market to you. We will obtain your opt-in consent to such sharing of your Personal
Information when we present you with the terms of such offer. If you have opted-in for this kind
of sharing, then you may: (i) choose to opt-out of such sharing by contacting us as set forth
below; or (ii) request certain information regarding our disclosure of such information to such
non-affiliated third parties by contacting us as set forth below. Further, if you would like to optout of Stocky5 sharing of your Information with its affiliates so that such affiliates cannot use
your Information to market to you, please contact us as set forth below at the end of this policy.
You may access, review, and make changes to your Personal Information by following the
instructions found on the Community Platform. In addition, you may manage your receipt of
marketing and non-transactional communications by clicking on the “unsubscribe” link located
on the bottom of any Stocky5’s marketing email.
We may send you push notifications through our 5paisa’s mobile application. You may at any
time change your preferences from receiving these types of communications by changing the
settings on your mobile device. We may also collect location-based information if you use our
mobile applications. You may update this by changing the settings on your mobile device.
You may stop or restrict the placement of Technologies on your device or remove them by
adjusting your preferences as your browser or device permits. The online advertising industry
also provides websites from which you may opt out of receiving targeted ads from data
partners and other advertising partners that participate in self-regulatory programs.
Alternatively, for some devices you may use your device’s Community Platform controls in
your settings to exercise choice.
YOUR PRIVACY RIGHTS
In accordance with applicable law, you may have the right to:
- Access Information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Information transferred to another party;
- Request correction of your Personal Information where it is inaccurate or incomplete;
- Request deletion of your Personal Information, subject to certain exceptions prescribed by law; and
- Request restriction of or object to processing of your Personal Information, including the right to opt in or opt out of the sale of your Personal Information to third parties, if applicable, where such requests are permitted by law.
If you would like to exercise any of these rights, please log into your account or contact us as set forth below in this policy. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
DATA RETENTION
We store the personal information we receive as described in this Privacy Policy for as long as you use the Community Platform or as necessary to fulfill the purpose(s) for which it was collected, provide our services on the Community Platform, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
HOW WE PROTECT YOUR INFORMATION
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We maintain physical, electronic, and procedural safeguards that comply with applicable state and federal laws and regulations to guard non-public personal financial information from unauthorized access, use, and disclosure. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information you supply will not be intercepted while being transmitted to and from us over the Internet.
MINOR
The Services are not directed to ANY MINOR, and we do not knowingly collect personal
information from minor. If you learn that your child has provided us with personal information
without your consent, you may contact us as set forth below in this policy. If we learn that we
have collected any personal information in violation of applicable law, we will promptly take
steps to delete such information and terminate the child’s account.
Stocy5 does not monitor, recognize, or honour any opt-out or do not track mechanisms,
including general web browser “Do Not Track” settings and/or signals
EXTERNAL WEBSITES
This Community Platform may contain links to third-party websites and has no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and you agree to keep yourself updated by visiting the website. By accessing the Website or app or using this Community Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer to this Privacy Policy on a regular basis.
If you have questions about this Privacy Policy or any requests pertaining to your privacy, please e-mail us at support@5paisa.com