Last Revised: 29 November 2017
Links to Third Party Websites
Voluntary Disclosure to Third Parties
Competency to Contract
Can You Opt-Out of Sharing your Information?
What Information Do We Collect?
We may collect and process the following data about you:
A. Verification Information. If you register / attempt to register as a User of our Website, you may be required to give us personal information about yourself. The minimum information you give us may include without limitation your name, postal address, e-mail address and phone number. There may be restrictions on your use of the Services at this stage.
If you request us to give you access to additional Services such as increased buy and sell limits, transfer any funds to your Linked Bank Account or third-party digital asset wallets, or correspond with us by phone, e-mail in order to troubleshoot problems reported by you or otherwise, you may be required to give us additional sensitive personal information which we may share with Third Party Service Providers acting on our behalf to verify your identity or address, and/or to manage risk. This sensitive personal information you give us may include without limitation your Aadhaar Number, information about/images of your taxpayer identification number (such as a PAN), your government-issued identification documents, your date of birth, your photograph, details of your Linked Bank Account and digital asset wallets held on third-party exchanges/websites, or other information requested by us to detect and protect against frauds and similar criminal activity, and such other information required by us from time to time for providing the Services.
We may also occasionally require you to participate in optional surveys. Your personal information may be collected through such surveys.
Further, we may also require additional information about you for performing on-going due diligence (necessitated under the applicable law) based on your risk assessment, transaction value, etc.
B. Automatically Collected Information. During each of your visits to our Website, we may automatically collect and analyse demographic and other information, including without limitation, (a) technical information about your device, including its operating system and the browser, the IP address being used, location and other similar information; (b) information about your activity, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); information about transactions and trades executed or attempted to be executed by you; material or information that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); (c) information about fund-transfer requests, executed while accessing Services through our Website. In such transactions, we may collect information relating to such transactions provided by you or by a Selected Third Party; and (d) Metadata and other technical data associated with the content you submit, post or share on the Website. Users can add or may have metadata added to their content including geolocation, date, attribution, or other data.
C. External Information. We may receive information about you from external sources such as from your use any of the other websites/apps we operate or the other Services we provide. Such data may be shared internally and combined with data collected through your use of the Website. We also work closely with select third parties (including, for example, sub-contractors such as advertising networks, analytics providers, search information providers) and may receive information about you from such sources.
D. Statistical Information. We collect non-personally identifiable information to track the total number of visitors to our Website in aggregate form and identify the type of Internet web browser (e.g. Google Chrome®) and operating system (e.g. Windows®) used by the visitor. This information allows us to improve the Website and Services continuously.
We request you to ensure that all your data and/or information shared with us is accurate, correct and complete, at all times, and you must promptly inform us of any changes to your data and/or information which may impact your use of our Services. You understand that we shall not be liable or responsible for the authenticity of your data and/or information, and any loss or damage that may occur to you or other third parties on account of the incorrect data and/or information being provided by you.
How Do We Use Your Personal Information?
As a matter of practice, we will use your personal information only for the following purposes and inform you in advance if any purpose is changed:
A. Verification Information. We will use this information:
- to verify and process your personal particulars;
- to inform you of promotions, offers, surveys, events, products, and services, which may be of interest to you;
- to facilitate and provide the Services offered through our Website.
- to update and back-up our records;
- to carry out our obligations arising from any contracts entered into by you with other Users of our Website (including processing of any transactions executed or attempted to be executed by you) and to provide you with the information and Services, that you request from us;
- to enhance the security of our Website;
- to personalise content/Services offered to you;
- to remember information to help you efficiently access your Account;
- to provide you with information about other Services we offer that are similar to those that you are already using or have enquired about;
- to provide you, or permit Selected Third Parties to provide you, with information about Services we feel may interest you. If you are a registered User, we will only contact you by electronic means (e-mail or SMS) with information about services similar to the Services being used by you.
- to notify you about any changes to our Services;
- to ensure that content from our Website is presented in the most effective manner for you and for your computing device.
- to send you Service-related notices or emails and other non-essential promotional material. In case you do not wish to receive such e-mails or SMS, you may unsubscribe at any time by clicking on ‘Unsubscribe’ or by contacting our Grievance Officer.
- for KYC verification of the details of PAN and other identification documents provided by you. You understand that in order to verify that such information belongs to you: (a) we may send you a verification e-mail; and (b) share all such information with a Selected Third Party. If you are a new User, such Selected Third Party or our representatives may contact you for the purposes of verification and authentication of your identification documents;
- to prevent and identify suspicious /other illegal transactions in order to mitigate risks relating to money laundering and other illegal activities.
B. Automatically Collected Information. We will use this information:
- to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Website to ensure that the content is presented in the most effective manner for you and for your device;
- to allow you to participate in interactive features of our Services, when you choose to do so;
- as part of our efforts to keep our Website safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to better understand the volume of traffic to particular areas of our Website.
- to make suggestions and recommendations to you and other Users about Services that may interest you or them.
- for fulfilling our obligations under applicable law including performing on-going due diligence and reporting suspicious/other illegal transactions.
- as part of our security, anti-fraud, and authentication checks in order to mitigate risks relating to money laundering and other illegal activities.
- in order to comply with directions of various law enforcement agencies/regulators.
C. External Information. We may combine this information with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive)
D.Statistical Information. We may share statistically anonymised information with third parties or publish generic transactional information relating to the trades undertaken on the Website such as current and historical bids, asks, and market prices; opening and closing range prices; high–low prices; trade prices; estimated and actual trade volumes; settlement prices; etc.
When Might We Disclose and Distribute Your Personal Information?
We will only distribute your information in accordance with the circumstances outlined in this section. However, you understand and acknowledge that generally, information published on a blockchain (including, without limitation, transactional information) is susceptible to public disclosure since any blockchain ledger is publicly accessible. As a result, Digital Asset transactions, whether executed on the Website or otherwise, are not truly anonymous. Similarly, the balance and transaction history of any public Digital Asset address can also be viewed by the public at large. Further, the information relating a public Digital Asset address can also be correlated / matched with technical information automatically collected over the Internet, in order to ascertain your identity. Also, data-analysis techniques can be used on a blockchain to identify information about you. You understand and acknowledge that we cannot be held liable for any loss of your information sustained due to the inherent lacunas of blockchain technology.
Besides, we reserve the rights to export your personal information and other data outside of India. Under those circumstances, your personal information may be processed and stored in a foreign country or countries, and the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your personal information under the relevant foreign laws.
We also reserve the rights to distribute any information that you (i) voluntarily disclose or chose to make public, or (ii) is freely accessible in public domain.
We further reserve the rights to distribute your personal information to any third party only under one of the following circumstances:
A. For Crime Prevention or Investigation. We may share this information with government/enforcement agencies or other companies assisting us, when we are:
- Obligated under the applicable laws or in good faith to respond to court orders and processes;
- Detecting and preventing against actual or potential occurrence of identity theft, fraud, money laundering, abuse of Services and other illegal acts; or
- Under a duty to disclose or share your personal data in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with third parties for the purposes of fraud protection and KYC verification.
B. For Activities of the Website
- Interaction with Users. You may routinely execute Digital Asset transfers on our Website. In order to process such transactions between you and other Users on our Website, we may share information about you with such User, including your email address or mobile phone number to inform such User that a transfer has been sent to or received by such User.
- Interaction with Non-Users. You may also choose to send Digital Assets to or request Digital Assets from an email address. In such cases, your username will be displayed in an email message notifying the user of the designated email address of your action.
- For Authorisation and Verification. We may use this information in connection with transfers to confirm that you are our customer, that Digital Asset transfers are enabled, and/or to notify you that you have received Digital Asset from a third-party storage service. If you request that we validate your status as our customer with a third party, we will do so. We may, from time to time, generally permit you to access your Account through one or more third-party applications. In such cases, the information you have provided to us may be shared with such third party applications. Based on the level of authorization you provide, these third parties may be allowed to use your information for any purpose other than facilitating your transactions using our Services
C. For Internal Use. We may share this information:
- With any member of our Group. The term “Group” includes means, with respect to any person, any entity that is controlled by such person, or any entity that controls such person, or any entity that is under common control with such person, whether directly or indirectly, or, in the case of a natural person, any Relative (as such term is defined in the Companies Act, 2013) of such person.
- In the event that we sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets.
- If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its Users will be one of the transferred assets.
D. With Selected Third Parties. We or our Group entities may disclose and share your personal information with selected business partners and third parties including but not limited to service providers who authenticate KYC and details as furnished/provided by the Users to the Company; scheduled commercial bank(s) which provide(s) banking facilities to the Company; payment processing companies; and credit rating agencies. (“Selected Third Party”).
E. With Advertisers and advertising networks. We do not disclose sensitive personally identifiable information about our Users to any advertisers, but we may provide them with aggregate information about our Users (for example, we may inform them that any given number of women in a specified age group clicked on their advertisement on any given day) to select and serve relevant adverts to you. We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
F. General Information of Public Interest. The Company reserves the right to share current and historical bids, asks, and market prices; opening and closing range prices; high–low prices; trade prices; estimated and actual trade volumes; settlement prices; and, other aggregate data and information related to the Digital Assets traded on the Website.
The use of such technology allows us to statistically monitor how many people are using our Website and those of our affiliates, or opening our e-mails, and for what purposes. We also use local storage to provide you (a) with a customised experience when you browse our Website and (b) to improve our Website, our Services, and advertising. Third parties may also use such cookies and tracking technology if you interact with any content provided by them through our Website, however, we endeavour to identify these cookies before they are used and allow you to accept or deny them.
Limited personal but anonymous information may be collected through the cookies and tracking technology, including but not limited to transaction information and other generic information such as number of visitors, device information, etc. Further, if any personal information has been previously provided, cookies may be tied to such information.
Cookie and tracking information collected by us may be shared with third-parties which directly support our advertising/promotional activities and are involved in the development of/updating our Website.
Commonly used browsers are set up to automatically accept cookies however you can modify your device’s settings to either alert you when you receive cookies or block cookies. If you disable/block cookies, it may affect the performance and functionality of our Website and may also restrict your experience. If you use different devices to access our Website, you would be required to modify each device’s settings individually to suit your cookie preferences.
How May You Access Your Personal Information?
Under the Act, you have the right to review the personal information we collect about you. To the best extent possible, we will attempt to ensure that such information is correct, and updated.
How Do We Keep Your Data Secure?
Sensitive Personal Information refers to data, whether true or not, about an individual: (i) who can be identified from that data; or (ii) from that data and other information to which we have or are likely to have access. Your personal data is accessible only by our authorized employees and Selected Third Parties and is otherwise kept secure.
We have in place appropriate technical and security measures to prevent unlawful access to or accidental loss of information collected including those prescribed under applicable laws. All information you provide to us is stored on our secure servers. We use firewalls on our servers. Any information collected during processing of payment transactions electronically will be encrypted using Secure Socket Layer (SSL) technology. Where we have given you (or where you have chosen) a username and password which enables you to access certain parts of our Website, you are responsible for keeping these details confidential. We ask you not to share your password with anyone. You must log out when you leave any section of our Website protected by a password. We recommend closing the browser completely and re-opening it before accessing other websites over the internet.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee, give no warranties, and shall not be liable for breach of the security of your data transmitted through the Website due to malicious attacks, errors, commission or omissions not wilfully initiated by us. Any transmission is at your own risk. Once we have received your information, we will use strict physical, electronic, and procedural safeguards to try to prevent unauthorised access.
How Long Do We Retain Your Data?
We may, at our sole discretion, retain any information and/or data provided by you for as long as your Account is active, for resolution of disputes, for the purpose of investigations or ongoing prosecutions or in case of any suspicious/illegal transactions, for enforcement of any agreements, and/or as necessitated under applicable laws. The retention period may be extended in accordance with the applicable law.
We make no warranties and shall not be liable regarding non–availability or non–retention of any information and/or data provided by you beyond the deletion of your Account.
What Rights Can You Exercise?
You may deal with your personal information available with us in the following ways:
- You may correct, amend, add or update personal information from your Account at any time by logging in to your Account.
- You are free to remove or delete your content from your Account at any point in time, provided, however, the Company may retain all or some of your data in accordance with the AML & KYC Policy in force or as per Applicable Law. Copies of public content may be retained indefinitely in our systems, including in cached and archived pages of our Website, or if other Users have copied or saved that information.