Privacy Notice
Tata Fintech Private Limited (“Tata Fintech” or “we” or “our” or “us”) owns and proposes to operate a trading and stock broking platform, which will be made available at the website www.tatafintech.com and our mobile application (collectively referred to as the “Platform”) through which Users (defined below), as per their suitability, can avail Services (defined below) offered and/or made available by us.
We take the privacy of your Data (defined below)seriously. This Privacy Notice describes the types of Data we collect, the purposes for which we collect Data, other parties with whom we may share it and the measures we take to protect the security of your Data. It also tells you about your rights and choices with respect to your Data, and how you can contact us about our privacy practices.
You are advised to carefully read this Privacy Notice before accessing our Platform and/or availing any Services.
1. SCOPE AND APPLICABILITY
Tata Fintech allows you to use/visit/browse the Platform without creating an account (“Account”). Your access to and/or usage of your Account is subject to your compliance with all the terms and conditions set forth in this Privacy Notice, read along with all documents, including but not limited to application forms and undertakings, accepted and/or signed by you during Account creation and/or registering for a trading/demat account on the Platform, and any terms/policies included on web platform/mobile applications under Tata Fintech’s domain including its “Terms of Use”, “Policies & Procedures”, and “Disclosures”.
This Privacy Policy applies to any person who has visited the Platform and/or who may or may not create and/or initiate the process of opening an Account. Tata Fintech shall at all times follow all such rules prescribed under the applicable Data Protection Laws (defined below), and rules & procedural guidelines set by the Securities Exchange Board of India (“SEBI”), the National Stock Exchange (“NSE”), the Bombay Stock Exchange (“BSE”), and Central Securities Depositories Limited (“CDSL”)and/or any of their respective regulated entities/intermediaries (collectively “Regulators”) that Tata Fintech is a member of.
2. DEFINITIONS AND KEY CONCEPTS
In this Privacy Notice, the following definitions are used:
Data
Personal data/information (as defined under Data Protection Laws) about you, which we collect, receive, or otherwise process in connection with your use of our Platform and as more specifically set out in Clause 2 below.
Cookies
A small file placed on your device by our Platform when you either visit or use certain features of our Platform. A cookie generally allows a website or mobile application to remember your actions or preference for a certain period of time.
Data Protection Laws
Any applicable law in India for the time being in force relating to the processing of Data.
Services
Services made available on the Platform (either by us or any third party) including in relation to stock broking, demat services, research analysis etc.
Service Providers
Entities which provide services to us and to whom we may disclose your Data or they may collect Data from you on our behalf for a specific purpose pursuant to an arrangement in accordance with applicable law.
Tata Fintech
Tata Fintech Private Limited, a company incorporated in India whose registered office is at Army & Navy Building, 148 M. G. Road, Fort, Mumbai 400001, India.
Tata Fintech is a trading member of stock exchanges (NSE and BSE), registered with SEBI and having Registration No. INZ000308636 and a depository participant with CDSL registered with SEBI and having Registration No.IN-DP-767-2024.
Tata Group Entity
Tata Fintech Private Limited, its parent company, promoter, subsidiaries, affiliates, group companies and the companies promoted by the foregoing.
User or you
The natural person who accesses our Platform.
3. WHAT DATA DO WE COLLECT ABOUT YOU
In the course of using our Platform and/or Marketbrew and/or any of the web platform/mobile applications under Tata Fintech’s domain or availing the products and services on any of Tata Fintech’s (and/or its affiliates) web platforms or mobile applications, Tata Fintech may become privy to some of your Data, including but not limited to the following categories:
(a) Personal information:name, age, employment status, nationality, date of birth, gender and other similar data.
(b) Contact information: email address, postal address, country, phone number and other similar contact data.
(c) Financial information:bank account, investment portfolio, credit history (including credit score), occupation,income, spending pattern or trends, and other similar data.
(d) Know Your Customer (“KYC”) information: Permanent Account Number (PAN), Aadhaar, Driving License, Passport and other similar proof of income, address proof, identity proof,FATCA details, residential status, PEP status, UBO information, etc.
(e) Transaction information: date of the transaction, transaction amount, transaction history, payment information (such as method, mode and manner of payment), demat holding and services under demat and other similar data.
(f) Account and/or trading/demat account specific information:Your photograph, signature image/specimen, password, father’s/mother’s and spouse's names and such other similar information.
(g) Technical information: Platform usage, Internet Protocol (IP) address, access to your device (such as camera or location), device information (such as IMEI number, model, OS system etc.) and similar information collected via automated means, such as cookies, pixels and similar technologies.
(h) Feedback information: Your reviews, feedback, opinions, correspondences about our Platform and Services.
You can make choices about our collection and use of your Data. For example, you may want to remove your Data on our Platform. When you are asked to provide Data, you may decline. For more information, please see the section below, titled “Your Rights and Choices”.
4. HOW WE COLLECT DATA
We collect Data in the following ways:
(i) Information You Give Us: We receive and store any information you enter on our Platform or give us in any other way. For instance:
(a) when you register to create an Account with us,in order to avail the Services offered on our Platform;
(b) when you conduct/attempt a transaction on our Platform;
(c) when you use the Platform;
(d) when you share and/or upload information/documents, as and when you avail any Services on our Platform;
(e) when you complete surveys conducted by or for us;
(f) when you elect to receive any communications (including promotional offers) from us;
(g) from the information gathered by your visit to any of the web platform/mobile applications under Tata Fintech’s domain and/or your participation in any marketing program or promotions conducted by or for us; and
(h) When you send correspondence to us through email, calls or any other medium.
(ii) Data That We Collect Automatically: We use Cookies, pixels and similar technologies to receive and store certain types of information whenever you interact with us.For instance:Our Platform may place and access certain Cookies on your device. We also use pixels and similar technologies to analyse traffic on our Platform to improve User experience.
(iii) Information from Other Sources: We may obtain information from other sources. Examples of this is:
(a) When you authorize a third-party website (such as the website of another Tata Group Entity) to interact directly with our Platform to provide or receive information about you. In that case, we may receive information to identify your account with that website or for facilitating your access to our Platform through single sign on.
(b) We may retrieve your records available with third parties such as KYC Registration Agency (“KRA”), CKYC, NSDL, Registrar and Transfer Agent (RTA) etc.
(iv) Information Previously Provided to Tata Group Entities:
Where you have shared any information previously with any of the Tata Group Entities and such Tata Group Entity is permitted to further share such information, it will share such information with us.Regardless of the terms on which you had originally provided the information to a Tata Group Entity, you acknowledge that: (a) we will collect such information from such Tata Group Entity for the purposes set out in this Privacy Notice; (b) the Tata Group Entity that provides such information to us is subject to its own compliance obligations under the applicable law, and (c) we are not responsible for any acts or omissions of such Tata Group Entity in relation to any such compliance obligations under the applicable law.
5. OUR USE OF DATA
Data collected by us may be used by us for the following reasons:
(a) carry out our obligations arising from any contract entered into between you and us, including to provide Services;
(b) identity verification and background check for Account creation as per applicable KYC & anti-money laundering laws;
(c) provide products and/or services and communicate with you about products and/or services offered by us including processing any transactions;
(d) provide you with personalized services, recommendations and improve your experience on our Platform, including, where permitted under applicable law, by storing and/or using your information to enable future interactions/transactions on Platform to run more smoothly;
(e) checking your eligibility and/or providing you access to the products and/or services being offered by us and/or by any third party (“Third Party Product Providers”) through our Platform.
(f) operate, evaluate and improve our business, products, services and Platform;
(g) generate aggregated data to prepare insights to enable us to understand customer behaviour, patterns and trends with a view to learning more about your preferences or other characteristics;
(h) provide marketing and promotional campaigns to you based on your profile;
(i) communicate with you (including to respond to your requests, questions, feedback, claims or disputes) and to customize and improve our products and/or services;
(j) enforce the terms and conditions arising from any contract entered into between you and us
(k) protect against and prevent fraud, illegal activity, harm, financial loss and other legal or information security risks; and
(l) serve other purposes for which we provide specific notice at the time of collection, and as otherwise authorized or required by applicable law.
6. SHARING OF DATA
We may share your Data in the following ways:
(a) Third Party Product Provider, Regulators and Financial Institution:We make available to you products and/or services including those that are provided by Third Party Product Service Providers through our Platform. If you choose to avail such products and/or services, Data required for you to avail such such products and/or services will be shared with such Third Party Product Provider. We may also share your Data with:
(i) Regulators for the purpose of processing your transaction requests and/or serving you better.
(ii) with financial institutions such as banks, KRA, RTAs, NSDL, CKYC credit information companies etc. for the purpose of reviewing your profile and processing your transaction requests for the Services and/or for facilitating other products/services offered by us and/or such financial institutions and/or Third Party Product Provider.
Use of your Data by Third Party Product Provider, Regulators and financial institutions is subject to their own privacy policies. For further information on how these entities process your Data, please refer to their privacy policies.
(b) Service Providers: We may share your Data with Service Providers who may, in the course of providing their respective services, receive and process Data. Examples include providing single sign-on, storing data, protecting and securing our systems, providing search results and links, providing customer service, aiding with our KYC and anti-money laundering obligations, providing digital signature facilities, credit analysis, fraud prevention, processing your data for profiling and analytics.
These Service Providers will be required to only process Data in accordance with our instructions. The Service Providers will also be required to safeguard the security and confidentiality of the Data they process by implementing appropriate technical and organizational security measures.
(c) Protecting Tata Fintech and Tata Group Entities: We may release Data when we believe that disclosure is reasonably necessary (a) to comply with applicable law, regulation or statutory notices and/or orders; (b) to protect Tata Fintech's intellectual property rights; (c) to protect Tata Fintech against harm or financial loss; (d) when we believe disclosure is necessary to protect individuals’ vital interests, or (e) in connection with an investigation of suspected or actual fraudulent or illegal activity. This may include exchanging information with other persons, companies and/or organizations for fraud protection, risk management and dispute resolution.
(d) Business Transfers: As we continue to develop our business, we might undergo corporate restructuring or sell or buy subsidiaries or business units. Your Data may be transferred as part of such transactions.
(e) Third Parties: We may also share your Data with other third parties where:
a) You request or authorize us to do so;
b) We need to comply with applicable law or regulation or statutory notices and/or orders; or
c) We need to operate and maintain the security of our Platform, including to prevent or stop an attack on our computer systems or networks.
The sharing of your Data will be in line with the processes set out in this Privacy Notice.
7. AADHAAR INFORMATION SPECIFIC TERMS
(a) You hereby understand and agree that providing your Aadhaar information to us is completely voluntary. Your Aadhaar information is only required for completing your trading/demat account creation process online and for digitally signing the account opening form. Your Aadhaar may also be used as a proof of address as an alternative choice to driver’s license or Passport copy, subject to you giving us your voluntary consent.
(b) Tata Fintech does not store any Aadhaar information other than (1) the last four digits of your Aadhaar / VID (Virtual ID created on the UIDAI website), (2) full name, (3) date of birth, (4) gender, (5) address, and (6) your photo.
8. MINORS
The Platform is intended for Users who are at least 18 years old. Persons under the age of 18 are not permitted to access the Platform or create an Account and/or register for trading/demat account except through a legal guardian. We do not knowingly accept, request, or solicit information from minors or knowingly market to children.
9. WHERE WE STORE DATA
We store your Data in accordance with applicable law and on secure servers located in India.
10. KEEPING DATA SECURE
We will use technical and organisational measures to safeguard your Data. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us by e-mail.
The security of your Account depends on you keeping your account password(s), PINs and/or other access information confidential. If you share your Account information with a third party, they will have access to your account and your Data.
It is your responsibility to control access to your Account, including keeping your password(s) and/or PIN confidential and not sharing it with anyone. It is also your responsibility to alert us if you believe that the security of your Data in the Platform has been compromised.
11. RETENTION OF DATA
Tata Fintech retains Data for as long as necessary for allowing you the access to/use of our products and/or services or to facilitate your access to and use of our Platform, or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements; and as long as processing and retaining your Data is necessary for our legitimate interests and operations. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly.
12. YOUR RIGHTS AND CHOICES
Subject to applicable law, you may be entitled to exercise following rights in relation to your Data stored with us:
(a) Right to Confirmation and Access - you may ask us to confirm what Data we hold about you at any time, and request us to modify or update such Data. You may also request a copy of the Data we hold about you.
(b) Right to Rectification - you have the right to request that we rectify any inaccurate or incomplete Data that we hold about you, including by means of providing a supplementary statement.
(c) Right to Restrict our Use of your Data - you have the right to request that we restrict our processing of your Data in certain circumstances, for example if you dispute the accuracy of the Data that we hold about you or you object to our processing of your Data(including where we process your Data for our legitimate interests, where permitted under applicable law).
(d) Right to Withdraw Consent – where we have obtained your consent to process your Data for certain activities, you may withdraw this consent at any time, and we will cease to carry out that particular activity that you previously consented to unless we consider that there is an alternative legal basis to justify our continued processing of your Data for this purpose.
To get in touch with us about these rights, or for more information about managing your Data and promotional communications, please use the contact details set out in the section below, titled “How to Contact Us”. Please note that we may keep a record of your communications to help us resolve any issues which you raise. Where we are legally permitted to do so, we may refuse your request.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
13. SEVERABILITY
If any court or competent authority finds that any provision of this Privacy Notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Notice will not be affected.
14. LINKS TO OTHER WEBSITES
Our Platform may, from time to time, provide links to websites and/or applications of third parties and Regulators whose privacy practices differ from those of Tata Fintech. We have no control over such websites and applications and are not responsible for the content of those websites and applications. If you provide Data to any of those websites or applications, then the use of your Data is governed by their privacy notices. This Privacy Notice applies to our Platform only.
15. CHANGES TO THIS PRIVACY NOTICE
Our business changes constantly and our Privacy Notice will also change. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our Platform frequently to see recent changes. The updated version will be effective as soon as it is available on Platform. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your Data.
16. HOW TO CONTACT US
To request a review or update, your Data or to otherwise reach us, please submit a request by e-mailing us at customerservice@tatafintech.com. You may contact us for information on Service Providers, and other persons with whom we may share your Data in compliance with this Privacy Notice and applicable law. We will respond to your request within 30 days.
17. GRIEVANCE OFFICER
Please see below the details of our grievance officer:
Email: complaints@tatafintech.com
Address: 1st Floor, Army & Navy Building, 148, M G Road, Opposite Kala Ghoda, Fort, Mumbai, 400001, India.