Privacy Policy

1. Sources of Personal Information

Alloc8 collects Personal Information about you from a variety of sources, including through:

1. your online and electronic interactions with us including via our Platform, via chat bot, online campaigns, transaction link and other new channels as and when they are introduced, such as WhatsApp.
2. your offline interactions with Alloc8, including via hard copy registration/application forms, and contacts through Alloc8 consumer services call centres;
3. your interactions with us through your communications and interactions with us through emails, recordings at our call centres, etc.;
4. third-parties (including but not limited to Payment Processors, service providers and/or agents); and
5. our Affiliates.

The information being collected is the basis of our ability to provide you with good, qualitative, timely and efficient service, while also keeping the information and data provided totally secure and confidential.

2. Datasets That We Collect

I. We collect, use, store, transfer, or otherwise process Personal Information about you to the extent permissible under Applicable Laws. Such Personal Information includes but is not limited to:

1. Your name and contact information, such as your residential address, business/ office address, email address, telephone number, mobile number or fax number;
2. Information relating to your identity including your date and place of birth, age, gender, nationality, Permanent Account Number (PAN) Details and country of domicile and/or your nationality; etc.
3. Information relating to your work (if self-employed, the nature of the self-employment) and income;
4. Financial information such as bank account details, (including information in relation to change in bank accounts), beneficiary account number, type of accounts held, bank statements;
5. Purchase and payments-related information such as payment records, payment method, cardholder data, bank account holder details, amount and date of payments, phone number, fax number, email address;
6. Generation and storage of passwords (PIN) in encrypted form based on a request from the investor under the online mode of investment;
7. Photographs and signature;
8. Device data including your internet protocol (IP) address, the internet service provider, your browsing history, device identity, mobile operator, WiFi connection, service set identifier (SSID), International Mobile Subscriber Identity (IMSI), International Mobile Equipment Identity, etc.);
9. Location data that describes the precise geographic location of your device;
10. Behavioural details regarding how you utilise our products, services, offers, etc.;
11. Marital status, gender, occupation;
12. Social relationship details such as your father’s name, spouse’s name, mother’s name, anniversary date, nominee details;
13. Details of your communications and transactions with us.
14. Information that we receive from third parties such as KYC Registration Agencies (KRAs), Asset Management Companies (AMCs), Registrar and Transfer Agents (RTAs), banks, payment service providers, intermediaries, regulatory authorities, analytics providers, and publicly available sources, to the extent permitted under applicable law.
15. Non-identifiable or illustrative inputs provided by users while using tools, calculators, or simulation features on the Platform, including but not limited to assumed investment amounts (such as SIP amounts), tenure, expected returns, inflation rates, and similar parameters. Such inputs are used solely for generating illustrative outputs and analytics and shall not be treated as Personal Data unless they are capable of identifying an individual or are linked to a specific user profile.
16. Any other information that you may share with us or that we collect from you while you visit, access or use our Platform or contact us for query resolution; and

We may also collect, use, and share aggregated data such as statistical or demographic data including your interests, age, general location, language preferences, and gender for any purpose. Aggregated data could be derived from your Personal Information but is not considered Personal Information under Applicable Laws. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the Platform. All rights, title, and interest in and to such aggregated data, including all intellectual property rights therein shall belong to and with Alloc8.

For the avoidance of doubt, the Company distinguishes between Personal Data and non-identifiable or aggregated data. Data that does not directly or indirectly identify an individual may be used for analytics, research, product development, and improvement of services without restriction, in accordance with applicable law.

Alloc8 shall not be responsible for verifying the accuracy or completeness of the Personal Information provided by you.

3. Purpose of Collection

i. The Company collects, uses, stores, and otherwise processes Personal Data solely for lawful, specific, and legitimate purposes in connection with its business of distribution of financial products (including but not limited to mutual funds, specialised investment funds (SIFs), insurance products, fixed deposits, bonds, and other financial instruments), operation of its digital platforms, provision of analytical tools and user engagement features, and compliance with applicable laws and regulations, including those prescribed by SEBI and the Digital Personal Data Protection Act, 2023.

ii. The Personal Data is further processed for the purpose of providing, enabling, and improving investment-related services, including facilitating transactions in mutual fund schemes such as subscriptions, redemptions, switches, and systematic investment plans, maintaining and updating investor folios, processing payments, and ensuring proper settlement of transactions. The Company may also use such data to assess suitability and appropriateness of financial products for users, including conducting risk profiling, understanding investment objectives, financial goals, risk appetite, and investment horizon, as required under applicable SEBI regulations.

iii. Additionally, Personal Data may be used for maintaining records of transactions, communications, and instructions, providing customer support, addressing queries and grievances, and ensuring effective service delivery. The Company may also process such data for internal business purposes such as analytics, auditing, monitoring usage patterns, improving platform functionality, enhancing user experience, developing new products or services, and ensuring system security, including detection and prevention of fraud, unauthorized access, and other illegal activities.

iv. Personal Data may further be processed for the purpose of complying with legal and regulatory obligations, including disclosures to regulators, statutory authorities, auditors, or law enforcement agencies, maintenance of records as required under applicable laws, and responding to lawful requests or orders. The Company may also use Personal Data to communicate with users regarding their transactions, account-related updates, regulatory disclosures, service-related notifications, and, where permitted, for marketing or promotional purposes, subject to obtaining appropriate consent where required.

v. In addition, the Company may process Personal Data received from third parties, including KYC Registration Agencies (KRAs), Asset Management Companies (AMCs), Registrar and Transfer Agents (RTAs), banks, and payment service providers, for the purposes set out above and in accordance with applicable law. The Company ensures that Personal Data is processed only to the extent necessary for the specified purposes and in compliance with the principles of data minimisation and purpose limitation under applicable data protection laws.

vi. Alloc8 may process limited user-provided inputs in connection with the use of platform features such as Safal Zenith, Safal Score, and financial calculators. These inputs may include investment preferences, hypothetical investment amounts, tenure, expected returns, inflation assumptions, and similar parameters, and are processed solely for generating illustrative outputs, analytics, and comparisons.

vii. Alloc8 may process Personal Data in connection with referral or user engagement programs, including tracking referrals, onboarding activities, and allocation or redemption of rewards or credits. Such processing is undertaken solely for the operation, administration, and compliance of such programs and in accordance with applicable laws and regulatory requirements.

4. Sharing/Transfer/Disclosure of Personal Information

1. The Company may share, transfer, or disclose your Personal Data to third parties strictly on a need-to-know basis and only for lawful purposes in connection with the provision of its services, compliance with applicable laws, and operation of its business.
2. In the course of providing distribution of financial products and related services, including mutual funds, specialised investment funds (SIFs), insurance products, fixed deposits, bonds, and other financial instruments, the Company may share your Personal Data with Asset Management Companies (AMCs), Registrar and Transfer Agents (RTAs), KYC Registration Agencies (KRAs), depositories, payment service providers, banks, and other financial institutions for the purposes of processing transactions, maintaining investment records, completing KYC and verification processes, facilitating payments and settlements, and ensuring regulatory compliance. The Company may also share such information with its affiliates, group entities, service providers, technology partners who assist in the operation of its platform, customer support, data storage, analytics, auditing, and other business functions, provided that such entities are bound by appropriate contractual obligations to maintain confidentiality and process such data only for specified purposes.
3. The Company may disclose Personal Data to regulatory authorities, statutory bodies, law enforcement agencies, courts, tribunals, or other governmental authorities, where such disclosure is required to comply with applicable laws, regulations, legal processes, or lawful requests, including obligations under SEBI regulations, anti-money laundering laws, tax laws, and other applicable frameworks. Such disclosures may be made without prior notice to you where required under law.
4. In certain circumstances, the Company may transfer or disclose Personal Data as part of a corporate restructuring, merger, acquisition, sale of assets, or similar transaction, provided that the recipient of such data agrees to adhere to standards of data protection and confidentiality consistent with this Policy and applicable laws.
5. The Company may also share anonymised or aggregated data, which does not identify any individual, with third parties for purposes such as analytics, research, and business improvement. Such data shall not be considered Personal Data under applicable laws.
6. The Company shall ensure that any sharing, transfer, or disclosure of Personal Data is undertaken with appropriate security measures and contractual safeguards to protect the confidentiality and integrity of such data.

5. Marketing Communications

To the extent permitted under Applicable Law, we may send you marketing communications about our products, services, or Updates, either electronically or physically from time to time. You can withdraw your consent or opt out of receiving such communications at any time by following the instructions provided in our communications or by contacting us directly. Please note that even if you opt out of marketing communications, we may still send you service-related or transactional messages that are necessary for the performance of our services.

6. Retention of Personal Information

Alloc8 shall not retain your Personal Information for longer than necessary to serve the purpose for which it is sought, or is otherwise required to be retained under any Applicable Law or our data retention policies, if any.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and requirements under Applicable Laws.

7. Cross-Border Transfers

Please note that all your Personal Information is only stored on systems located within India. We do not transfer your Personal Information to any third country.

8. Use of Mobile Applications

In case you use any facilities/products/services through the Application, any Additional Terms and Conditions governing the manner of usage of the Application, including collection and disclosure of Personal Information, shall be applicable and the same shall be read in conjunction with this Privacy Policy.

9. Third Party Services and Links to Other Sites

The Platform may contain services provided by or links to and from the websites of Third Party Services Providers. Please note that the Third Party Services that may be accessible through the Platform are governed by their own privacy policies. We do not accept any responsibility or liability for the policies or for any Personal Information that may be collected by providers of such Third Party Services. Please check their policies before you submit any Personal Information to their websites or use their services.

10. Children’s Personal Data

Alloc8 does not knowingly collect or process Personal Data of individuals below the age of eighteen (18) years (“Children”), except where such processing is necessary for investments made in the name of a minor through a parent or lawful guardian, as permitted under applicable SEBI regulations. In such cases, Personal Data of the minor shall be processed only with verifiable consent of the parent or guardian and strictly for lawful and limited purposes.

Alloc8 shall ensure that no tracking, behavioural monitoring, or targeted advertising is carried out in relation to Children’s data, in compliance with the Digital Personal Data Protection Act, 2023. If Alloc8 becomes aware that Personal Data of a Child has been collected without appropriate consent, it shall take steps to delete such data or obtain the required consent in accordance with applicable law.

11. Security of Data

To protect your Personal Information from unauthorised access or disclosure, loss or misuse, we have adopted reasonable security practices and procedures in line with industry standards. The transmission of information is not completely secure for reasons beyond our control. We adopt industry standard security measures and keep updating our systems from time to time to protect your Personal Information against any hacking or virus dissemination.

12. Change in Privacy Policy

Alloc8 reserves the right to change the Privacy Policy at any time. Please note that any such changes to the Privacy Policy will be effective from the date of posting the updated version of the Privacy Policy on the Platform.

13. Your Rights

In accordance with applicable laws, you have the right to access and obtain a summary of the Personal Data processed by Alloc8, along with information regarding how such data is being used. You may request correction or updating of any Personal Data that is inaccurate, incomplete, or outdated, and you may also request deletion of your Personal Data, subject to applicable legal and regulatory requirements.

You have the right to withdraw your consent for processing of your Personal Data at any time. Please note that withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal, and may impact Alloc8’s ability to provide certain services.

Please note that Alloc8 and any person acting on its behalf shall not be responsible for the authenticity of the Personal Information or sensitive personal data or information supplied by you.

You may also exercise your right to nominate another individual who may, in the event of your death or incapacity, exercise your rights in relation to your Personal Data, in accordance with applicable law.

14. Governing Law

This Privacy Policy shall be governed by the law of the republic of India, without respect to its conflicts of laws principles. Each of the parties to this Privacy Policy consents to the exclusive jurisdiction and venue of the courts located in Mumbai, Maharashtra, India for any actions not subject to Dispute Resolution and Arbitration provisions as set forth below in (Dispute Resolution).

15. Dispute Resolution

Any claim, dispute or difference relating to or arising out of this Terms of Service and Platform Privacy Policy shall be referred to the arbitration, of a sole arbitrator appointed mutually. The arbitration shall be subject to the Arbitration and Conciliation Act, 1996 as may be amended from time to time. The seat and venue of arbitration shall be Mumbai, Maharashtra, India. The proceedings shall be undertaken in English. The arbitration award shall be final and binding on the parties.

16. Grievance Redressal

If you have any question about this Privacy Policy or any grievances relating to use or handling of your sensitive personal data may be brought to our notice by writing to our designated Grievance Redressal Officer:

Name: Mr. Ayush Bansal
Email ID: compliance@safalmoney.com
Contact No.: +91 99279 73457