Privacy Policy

This Privacy Policy ("Policy") of Billionbrains Garage Ventures Limited, a company registered under the Companies Act 2013, having its registered office at Vaishnavi Tech Park, South Tower, 3rd Floor, Survey No.16/1 and 17/2, Ambalipura Village, Varthur Hobli, Bellandur, Bangalore, Bangalore South, Karnataka, India, 560103 ("Company") is aimed at informing the users, members, unregistered visitors, etc. (hereinafter collectively referred to as "Users" or "You" or "Your") of the practices in relation to the storage, use, processing, and disclosure of personal information and personal data that You have chosen to share with us, when You use or access our mobile application, namely 'W by Groww("App) and/or our website hosted at https://w.groww.in/ ("Website"). The Website and the App shall hereinafter be collectively referred to as (the "Platform").

This Policy outlines the information collected by the Company, its subsidiaries, affiliates, and third parties from the Users, the purpose for which the information has been collected by the Company, its subsidiaries, affiliates, and third parties. details of persons/ parties with whom the information so collected may be shared, and the Users' choice with respect to the uses and disclosures as contemplated herein. Usage of the terms "us", "we" or "our" under this Policy should be construed as a reference to the Company, and its subsidiaries, affiliates, and relevant third parties, as the case may be.

This Policy is applicable to all the information collected, received, possessed, controlled, dealt with, or handled by us in respect of a User. We, through this Policy, aim to demonstrate our commitment towards protecting Your personal data and respecting Your privacy in compliance with the Information Technology Act, 2000 ("Act"), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information), Rules, 2011 ("Rules"), and the Securities Exchange Bureau of India ("SEBI") rules, guidelines and other regulations in relation thereto (hereinafter collectively referred to as the "Guidelines"). We store and process Your information including any sensitive financial information collected, if any, on computers that may be protected by physical as well as reasonable technological security measures and procedures in accordance with Act and Rules thereunder. If You object to Your Information being transferred or used in this way, please do not provide the details of Your information on the Platform.

By using the Platform, You are accepting the practices as described in this Policy. You hereby expressly consent to provide below mentioned information to us for the purpose of providing the services offered through the Platform to You. We may seek Your consent through a separate consent form detailing required data points, purpose of collection, and disclosure of entities with whom such information might be shared, if so required by regulatory bodies.

If You disagree with any of the terms mentioned herein, please do not proceed with the usage of the Platform. You acknowledge that the Platform may contain links to other websites. If You click on a third-party link, You will be directed to that website. Note that these external sites are not operated by us. Therefore, it is strongly advised that You review the privacy policy of these websites/external links.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

In the situation that a term has been undefined in the Policy, it shall have the same definition as outlined in our Terms of Use, which You may access through here.

Information Collected by us

Personal Data and Information collected directly

While You can browse some sections of our Platform without being a registered member, most activities require registration and for You to provide the above details. We will indicate the mandatory and the optional fields against the information requested from You. You always have the option to not provide Your personal information by choosing not to use a particular service or feature on the Platform.

Personal Information: Personal information We collect from You includes any information concerning the personal or material circumstances of an identified or identifiable User, such as name, gender, residential/ correspondence address, telephone number, date of birth, marital status, email address or other contact information; PAN, know-your-customer ("KYC") status, signature and photograph; bank account or other payment instrument details; or any other detail for providing services including information such as username, account number, and password.

We offer the Platform for inter alia carrying out transactions that collect Your personal data and information to process Your financial and non-financial transaction requests. This facility enables investors like You to transact online through the Platform. The information collected shall be shared in connection with portfolio management services and additional Services, solely for the purpose of processing Your transaction requests and for serving You better.

Collection of Other Non-Personal Information

Additional Information: We track certain information like pages visited, buttons clicked etc. about You, based upon Your behaviour on our Platform. We use this information to undertake research on our Users' demographics, interests, and behaviours, to better understand, protect and serve our Users and improve our Services. This information is compiled and analysed on an aggregated basis.

Cookies and Tracking Technology: We may use "cookies" as required on our Website. "Cookies" is a term generally used for small text files a website uses to recognize repeat users, facilitate the user's ongoing access to and use of the site, allow a site to track usage behaviour, and compile aggregated data that will allow content improvements and targeted advertising, preferences etc. Cookies themselves do not personally identify the User, but identifies the User device. Generally, cookies work by assigning a unique number to the computer that has no meaning outside the assigning site. For the purposes of this Policy, Users are informed that cookies also exist within the App when a browser is needed to view certain content or display an advertisement within the App.

Users are being made aware that we cannot control the use of cookies or the resulting information by advertisers or third parties hosting data on our Platform. If Users do not want information collected through the use of cookies, they may change the settings in the browsers that allows Users to deny or accept the cookie feature as per User's discretion and in the manner agreed by such Users. Further, our Policy does not cover the use of cookies by our partners and affiliates, including our Lending Partners, since we do not have access or control over such cookies.

Web Beacons: The web pages of the Website contain electronic images known as "web beacons", sometimes called single-pixel gifs, and are used along with cookies to compile aggregated statistics to analyse how the Website is used. Web beacons may also be used in some of our emails so as to know which emails and links recipients have opened, allowing such beacons to gauge the effectiveness of our customer communications and marketing campaigns.

Existing Information

If you have an existing account with the Company or utilise any additional services provided by the Company or its subsidiaries, you hereby consent to us fetching your existing information for the provision of Services.

We do not allow unauthorized access to Your non-public personal contacts or financial transaction SMS data with any third party.

Log File Information Collected and Stored Automatically:

If You visit/ log into our Website just to browse, read pages or download information, We gather and store certain information about Your visit automatically. This information cannot and does not identify You personally.

When You register with or view our Website, our servers automatically record certain information that Your web browser sends whenever You visit our Website. The kind of information that is gathered automatically include the type of browser You are using (e.g. Internet Explorer, Firefox, etc.), the type of operating system You are using (e.g. Windows or Mac OS) and the domain name of Your internet service provider, as well as the date and time of Your visit and the pages on our Website. We sometimes use this information to improve our Website(s) design, content and primarily to give You a better browsing experience.

Mode of Collection of Information

We may collect User information in a manner that includes the following:

• Information that the User provides to us with her/his explicit consent in a separate consent form by filling in registration / enrolment / signing up forms on the Platform and for KYC purposes.
• Information that the User provides when User writes directly to us by way of e-mail, letters, messages, etc.
• Information that the User provides to us over telephone. We may make and keep a record of the information shared by the Users with us.
• Information that the Users provide by completing surveys, a survey, poll, sweepstakes, contest or promotion scheme; and
• Information that the User provides merely by accessing/navigating through the Platform.

How we use the Information we collect

Our goal in collecting the information is to provide You with a Platform to render personalised services. We use the information on a need-basis for the purpose of providing You the Services in the following ways and in compliance with all applicable laws:

• Provision of services to You.
• To observe, improve, and administer the quality of services;
• To analyse how the Platform is used and diagnose technical problems;
• To make user data analysis and risk management;
• To send User surveys and marketing communications that we believes may be of User's interest;
• To analyse, conduct internal reviews, surveys and understand the Users, improve the content and features of the Platform;
• To notify You about any changes to the Platform;
• To enable Us to comply with legal and regulatory obligations;
• To enable Us to send administrative notices and service-related alerts to You;
• To enable Us to do market research, troubleshoot, protect against errors, undertake project planning, fraud and other criminal activities; and
• To enforce our Terms of Use.

Disclosure and Sharing of Information

Any disclosure by us to third parties is subject to the following:

• If we are under a duty to disclose or share Your personal information in order to comply with any legal or regulatory obligation or request, We shall not seek Your explicit consent.
• We shall share Your information with a third-party only on a need basis and only for the purpose stated hereunder, as per the applicable legal requirements.
• We may share Your information with a third party for the provision of additional services and to provide you with information about services that may interest you.
• We may share aggregated demographic information with our partners or affiliates. This is not linked to any personal information that can identify an individual person.

Except as required under applicable laws or pursuant to a court / government order, any information or data shared by us with third parties shall be disclosed pursuant to a confidentiality agreement which inter alia restricts such third parties from using the said data only for the purpose of provisioning the services to us, to enable us to provide Services to You, and also restrict further disclosure of the information unless such disclosure is for the purposes as detailed under such confidentiality agreement.

Merger/Acquisition/Restructuring of Business: We and our affiliates may share Your information with another business entity, should We (or Our assets) merge with, or be acquired by that business entity, or in the event We undergo re-organization, amalgamation, or restructuring of business. We and our affiliates will share/sell/transfer/license/convey some or all of Your personal information with another business entity to carry out any business activity or re-organization, amalgamation, restructuring of business or for any other reason whatsoever.

Update user Information

If any information provided by You changes, You may correct, delete inaccuracies, or amend information by sending an email with the updated details to [email protected]. We will make commercially reasonable efforts to undertake the requested changes in our then active database, as soon as reasonably practicable. We shall not be responsible for the authenticity of Your information, including personal information supplied to Us.

You may also correct such information by updating Your details on the Platform.

Your Rights

• Deny Consent: You shall have the right to deny consent for use of Your personal information, restrict disclosure of Your personal information to third parties, and revoke consent already granted to Us to collect personal information from You, and if required, exercise Your right to be forgotten.
• Withdraw Consent: You may withdraw Your consent to contact You, for the continued collection, use or disclosure of Your information, at any time, or make a request for deletion of Your account by raising a request on the App or by mailing Us at [email protected]. However, if You have availed any services from us, we shall have the right to continue processing Your information, till such services are concluded and/or for such period as may be allowed under applicable law. We shall not retain Your data and information if it is no longer required by Us and there is no legal requirement to retain the same.

NOTHING CONTAINED HEREIN SHALL RESTRICT OUR ABILITY TO PROCESS, STORE, OR DISSEMINATION YOUR DATA IF SUCH PROCESSING, STORAGE, OR DISSEMINATION OF YOUR DATA IS REQUIRED IN COMPLIANCE WITH APPLICABLE LAW.

Data Protection, Retention and Storage

Reasonable Security Practices for Protecting Information: We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of Your personal information. We cannot, however, ensure or warrant the security of any information You transmit to us and You do so at Your own risk. Once we receive Your transmission of information, we make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

To protect Your privacy and security, we take reasonable steps (such as requesting a unique password) to verify Your identity before granting You access to Your account. You are responsible for maintaining the secrecy of Your unique password and account information, and for controlling access to Your email communications from us, at all times. To ensure security of access to personal information and transaction details, the access to the secured zone of our Platform is restricted by the unique login ID and Password selected/provided by You. You should be very careful in handling the same and You should ensure that You do not reveal it to anybody, nor do You keep it in writing. You should keep changing Your password periodically, wherever required.

We implement cyber security policy for handling all security breaches in compliance with applicable laws and regulations. We shall store Your information and/or data for such period as may be required by Us to
(i) enforce Our legal rights and obligations against You; and
(ii) to ensure compliance with Our obligations and responsibilities under applicable laws.

We use reasonable safeguards to preserve the integrity and security of Your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment. To achieve the same, We use reasonable security practices and procedures as mandated under applicable laws for the protection of Your information.

The information as mentioned above provided to Us will be stored on our secure servers located within India.

Unauthorised usage of Information

You have a right to report a security incident to the Grievance Redressal Officer (detailed mentioned below). You are entitled to prevent unauthorised usage of Your information by Our personnel/agents by informing Us, within ten (10) days of being informed of the proposed use, that You do not wish to disclose such information.

You can also exercise this right at any time by contacting us at [email protected].

Exclusion and Disclaimer

This Policy does not apply to any information other than information collected by Us through the Platform. This Policy will not apply to any unsolicited information provided by You through Our Platform or through any other means including, not limited to, information posted on any public areas of the Platform.

Although, we take appropriate steps to maintain the security of personal information we collect from You, You must understand that the nature of the Internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended. We assume no responsibility of whatsoever nature as to make good the losses and damages You may incur, due to privacy and/or security breach of Your personal information.

Changes to Privacy Policy

We reserve the right, at Our sole discretion, to update, change or replace any part of this Policy by posting updates and changes to our Platform. It is Your responsibility to check the Platform periodically for changes. Your continued use of or access to the Platform or the services, following the posting of any changes to this Policy constitutes Your acceptance of such changes. In case of any material changes to the Policy, the Users may be notified by means of a notice on the Platform prior to such change becoming effective.

Severability

The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy.

No Waiver

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

Governing Law and Dispute Resolution

This Policy shall be governed by and construed in accordance with the laws of India and subject to the provisions of arbitration set out herein, the courts at Bengaluru, India shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Policy.

Grievance Redressal Officer

In accordance with the relevant provisions of the Act and Rules, the Company has designated the Grievance Redressal Officer. Users can contact the Grievance Redressal Officer with respect to any complaints or concerns regarding the handling, storage, disclosure of User information.

All issues can be addressed at the following:

Email address: [email protected]

The Grievance Officer can be contacted between 10:00AM and 6:00PM from Monday to Friday except on public holidays.