Komal Vardhan Financial Systems Private Limited, a company incorporated under the Companies Act, 2013 and having its registered office at C-7/227, Pocket 7, Sector 7, Rohini, Delhi, 110085 (hereinafter referred to as “WealthScore”), has developed, and owns, the website and the web portal: www.wealthscore.me
This privacy agreement between WealthScore and you (hereinafter referred to as “User”) constitutes a binding agreement for implementing and maintaining reasonable security practices and procedure for securing sensitive personal data or information, and inter alia provides and sets forth the general terms and conditions regarding the use of wealthscore.me and for handling of or dealing with the Information (as defined hereinafter) of all clients, customers, service recipients, and users of wealthscore.me.
This privacy agreement is applicable to all Information collected, received, possessed, owned, controlled, stored, dealt with or handled by WealthScore and is applicable to the User. For the purposes of this privacy agreement, the term “User” includes the User’s clients and customers.
1. Scope of Personal Information and Sensitive Personal Data or Information
a. Personal Information
Personal information of any User would mean any information obtained by WealthScore for the purposes of its business, including providing its services, that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with WealthScore, is capable of identifying such person/User.
b. Sensitive Personal Data or Information
Sensitive personal data or information means such personal information which consists of information relating to:
Provided that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force will not be considered to be sensitive personal data or information.
The personal information or sensitive personal data or information shall include the personal information or sensitive personal data or information of the persons availing or proposing to avail or buying or proposing to buy the services (including financial products) of WealthScore.
Personal information, and sensitive personal data or information, provided through wealthscore.me shall hereinafter, as the context may require, be referred to as “Information”.
2. Type of Information and the purpose:
WealthScore may require certain Information for providing information to the User, provision of services, other user benefits, for technical, legal and/or accounting purposes and for other agreed purposes.
Following are the indicative agreed purposes and type of Information that would be required by WealthScore:
a. Electronic newsletters (Dispatches)
WealthScore may provide a free electronic newsletter to the User. To provide this service, if subscribed by the User, WealthScore may gather the e-mail addresses of the User who voluntarily subscribe to this service. The User may remove himself from this mailing list by following the link provided in every newsletter that points users to the subscription management page. The User can also subscribe to the newsletters at the time of registration.
b. Message boards/forums
If this service is provided by WealthScore, the User of the site’s Message Boards and Forums may register separately for these services by providing the specified Information in order to post messages.
c. “Share this to a friend” Service
WealthScore may provide an option to the User for choosing to electronically forward a link, page, or documents to someone else by clicking “share this to a friend” via social media. If provided by WealthScore, the user must provide their e-mail address, as well as that of the recipient. This Information is used only in the case of transmission errors and, of course, to let the recipient know who has sent the e-mail. The recipient’s e-mail address and name shall be used only for sending such e-mails.
WealthScore may occasionally conduct user surveys to better target its content to its audience. WealthScore sometimes share the aggregated demographic information in these surveys with its sponsors, advertisers and partners. WealthScore never shares any of this information about specific User with any other user.
This also allows WealthScore advertisers to advertise more effectively and allows the User to receive advertisements that are pertinent to their needs.
Participation in these surveys is entirely optional.
e. Usage tracking
WealthScore tracks user traffic patterns throughout all of its websites/mobile application. However, WealthScore does not correlate this information with data about individual users. WealthScore does break down overall usage statistics according to a User’s domain name, browser type, device type, operating system and MIME type by reading this information from the browser string (information contained in every User’s browser).
WealthScore sometime tracks and catalogues the search terms that the User enter in WealthScore’s search function, but this tracking is never associated with individual users. WealthScore’s may use tracking information to determine which area of its website users like and don’t like, based on traffic to those areas. WealthScore does not track what individual users read, but rather how well each page performs overall. This helps WealthScore continue to build a better service for the User.
f. Automatic Logging of Session Data
WealthScore may collect IP addresses from the User, which together with browser and session information may be used for various purposes, including to (i) diagnose and prevent service or technology problems reported by the User associated with the IP address controlled by a specific web company or ISP; (ii) estimate the total number of users visitingwealthscore.me from specific territories; (iii) monitor and prevent misuse and/or abuse of the services available on or through wealthscore.me.
WealthScore may also collect information about the operating system and type of browser software being used and the activities conducted by the User while on wealthscore.me.
WealthScore may also record information about the usage of the website by a User, including the size and frequency of data transfer.
WealthScore may use this information as it helps WealthScore to evaluate what users are likely to visit on most, the way users are visiting its website, the number of users visiting various pages on the website, etc. It also helps WealthScore to rectify technical problems.
In the event that a User sends a SMS regarding any facility or service available on WealthScore's website or otherwise, WealthScore may collect any Information as it deems relevant in respect of such SMS, including the phone number from which such SMS was sent, the service provider which carries the phone number, the content of the SMS and the time/date of communication.
A cookie may also be placed by WealthScore’s /wealthscore.me ’s advertising server or third-party companies for the purposes of analysing the effectiveness of advertising on wealthscore.me.
i. To enhance experience
WealthScore uses certain Information to enhance the User’s experience on its website, whether to provide interactive or personalized elements on the sites or to better prepare future content based on the interests of the users.
WealthScore also requires Information for the purposes of its business, including providing its services.The User may have to provide WealthScore with certain Information such as his/her name, bank account details, mobile number, e-mail address, date of birth, PAN, sex, education, vocation, income details, KYC documents and such other information as WealthScore may require to process the subscription.
This information is collected through an online application form for several purposes inter alia:
While registering, the User will choose a password and is responsible for maintaining the confidentiality of the password and the account. The User is fully responsible for all activities that occur while using their password or account. It is the duty of the User to notify WealthScore immediately in writing of any unauthorized use of their password or account or any other breach of security. WealthScore will not be liable for any loss that may be incurred by the User as a result of unauthorized use of his password or account, either with or without his knowledge. The User shall not use anyone else's password at any time.
4. To communicate with the User
WealthScore may modify the scope of its services from time to time. If any services are provided or proposed to be provided to the User either on User’s request or otherwise, WealthScore will use the information given by the User to facilitate or provide such service. Also, if the User asks any query from WealthScore on the services being provided by WealthScore or any other questions, WealthScore may keep the Information such as User’s e-mail address, name, nature of the question, etc. to respond to the User’s question or to enable WealthScore in making its services or the website better.
WealthScore may send subscription confirmation, cancellation, payment confirmation, refund status, general modifications or any such other information relevant for the subscription, on the email address given by the User or via SMS or by voice call on the contact number given by the User at the time of buying the subscription. WealthScore may also contact the User by voice call, SMS or email in case the User could not or has not concluded the subscription/payment process, for any reason whatsoever and also to help the User for the same. The User hereby unconditionally consents that such communications via SMS and/or voice call by WealthScore is (a) upon the request and authorization of the User, (b) ‘transactional’ and not an ‘unsolicited commercial communication’ as per the guidelines of Telecom Regulation Authority of India (“TRAI”) and (c) in compliance with the relevant guidelines of TRAI or such other authority in India and abroad. The User will indemnify WealthScore against all types of losses and damages incurred by WealthScore due to any action taken by TRAI, Access Providers (as per TRAI regulations) or any other authority due to any erroneous compliant raised by the User on WealthScore with respect to the intimations mentioned above or due to a wrong number or email address being provided by the User for any reason whatsoever.
5. To provide services through or using third parties:
WealthScore may also collect, use, and sometimes disclose the User’s Information to third parties on confidentiality basis for the following purposes:
6. Connecting your Gmail Account
a. Who is requesting Google user data?
WealthScore is a financial assessment and advisory platform that utilizes all possible details in order to provide the best applicable financial advice for a user.
b. Access Right to be provided by User
User can choose to provide explicit consent to connect his/her Gmail accounts with his/her WealthScore account.
User can choose to enable WealthScore to access one or more of their Gmail accounts by connecting such account(s) with their WealthScore account. If User connect their Gmail account, WealthScore website/app will automatically access and analyze the contents of Gmails, from a small list of whitelisted senders that comprise of Registrar and Transfer Agents (such as Karvy Computershare Private Limited, Computer Age Management Services, etc.), in user’s email account(s) on an ongoing basis for the purpose of identifying documents related to the applicable Web/App Services availed by User, including mutual fund statements.
d. What data are we requesting?
WealthScore website/app will securely access and analyze the contents of User’s Gmails from Registrar and Transfer Agents (such as Karvy Computershare Private Limited, Computer Age Management Services, etc.).
We encourage User to review their information prior to signing in through the applicable service.
c. Why are we requesting Google user data?
WealthScore intends to provide User detailed analysis of their assets as represented in their mutual fund statements.
e. Access methods
Once linked, the applicable information will then be extracted from User’s Gmail into their WealthScore account so that User may access the same through WealthScore website/app.
WealthScore’s access to the Gmail account/s is authorized through the Gmail provider’s access mechanism. If User chooses to have WealthScore website/app track their mutual fund statements from Registrar and Transfer Agents, WealthScore website/app will securely store account details for each of user’s mutual fund investments, including user’s sign-in user name and authorisation tokens for tracked accounts. This information will be used to enable WealthScore website/app to automatically access User’s applicable mutual fund statements to analyze, extract, and store information securely from such accounts for use in WealthScore website/app.
User will be asked in each case whether User wants to connect his/her email account.
f. Data Security
WealthScore will access user’s email account through a secured and encrypted script.Further, the process of accessing Gmail account of the User shall be without any human intervention. The information collated will be strictly confidential and shall be dealt with in the manner as provided in this privacy agreement.
g. Delink Option
User is free to de-link their email connection with WealthScore at any time. User may manage his/her connections to email and de-link the same at any time from the website/app.
For example, Google Mail’s permission settings are located at: myaccount.google.com/permissions. A User may de-link the access to their email any time they wish at this URL.
7. Communication by email
The following are some indicative guidelines to assist in protecting Information:
Internet and intranet e-mail
If body of the e-mail, or any of its attachments, contains highly sensitive information, the sender should use additional measures such as password protection or alternative methods of distribution.
If confidentiality and privacy of the e-mail content is important, use an alternate communication vehicle.
WealthScore will retain the Information for such period as may be required for the purposes for which it is lawfully being used or is otherwise required under any other law for the time being enforced.
9. Request for information by an order under law or by a government agency
Notwithstanding anything contained elsewhere, any Information may be disclosed by WealthScore to any third party by an order under the applicable laws, without any consent or other obligation, or as required to comply with applicable laws.
10. Security Practice and Procedure
WealthScore shall endeavour to follow and/or endeavour to ensure adherence of reasonable security practices and procedures to secure sensitive personal data or information made available to it by the User. WealthScore may provide a copy of such reasonable security practices and procedures, followed by it or its host server, to secure sensitive personal data or information, if required by the User. At present, our third party server host follows ISO 27001 security management standard for data/information security.
11. Option not to provide Information
The User has the option not to provide all or any of the required Information to WealthScore. Further, the User shall also have the right to withdraw the Information already provided or withdraw the consent to use the Information, by due notice in writing. However, in case of such refusal or withdrawal, WealthScore shall have the option to refuse to provide its services for which the Information was required or provided or otherwise terminate the services being provided or agreed to be provided.
12. General rules and regulations for provision of information by the User:
The User shall not host, display, upload, modify, publish, transmit, update or share any information that —
13. Use of website
The User shall not use the website or the options and services for any illegal or unlawful activities. WealthScore reserves the right to remove any objectionable content provided by the User in its website, once the same comes to the knowledge of WealthScore or is pointed out by any other user.
WealthScore’s website and its content are copyright protected.
14. Exclusion of liability
WealthScore is not responsible for any errors, omissions or representations on any of its pages or on any links or on any of the linked web pages. WealthScore does not endorse any advertiser on its web pages in any manner. The User is requested to verify the accuracy of all information on his own before undertaking any reliance on such information. Notwithstanding its reasonable efforts in that behalf, WealthScore cannot control the information provided by any third party or its users. WealthScore is not responsible for checking or verifying the accuracy or legality of any material submitted on its website by any third party or its users and WealthScore shall not be liable for any loss or damages that may be caused due to the inaccuracy or illegality of the materials submitted on its website by such third parties and its users.
The User understands and agrees that any material and/or data downloaded or otherwise obtained through the use of wealthscore.me is done entirely at their own discretion and risk and they will be solely responsible for any damage to their computer systems or loss of data that may result from the download of such material and/or data.
WealthScore shall not be liable for any loss or damage that may cause to the User because of its inability to use the website or to avail the options and services for any technical reason or due to factors beyond the control of WealthScore. WealthScore reserves the right to refuse the grant of or terminate the options and free services including electronic newsletter (dispatches), messages board/forums, “share this to a friend” service, surveys and facility for having logging account without any information, if it deems necessary, and WealthScore shall not be responsible for any loss or damage that may be caused due to such refusal of grant or termination of options and free services.
Notwithstanding anything contained hereinabove, WealthScore will always make its best effort to ensure that the content on its websites or other information platforms is free of any virus or such other malware.
15. Non compliance
In the event the User fails to comply with this privacy agreement applicable for provision of Information or for access, usage or avail WealthScore’s services or resources including computer resources, WealthScore shall have the right to immediately terminate the access, usage or avail of such services or resources and require the User to remedy the non compliance.
16. Notification by User
In the event the User notices any breach of the confidentiality of the Information under this privacy agreement, the User shall take all steps to inform WealthScore of the same.
WealthScore may share the Information with other persons, such as directors, officers, senior executives or any other authorised person from WealthScore or any affiliate company, auditors, lawyers, technical consultants and other professional advisors.
All third parties receiving Information shall be under an obligation to keep it confidential and comply with data privacy laws applicable from time to time.
WealthScore shall not collect sensitive personal data or information unless it is considered necessary for the purpose for which it is collected.
18. Access requests
The User shall be entitled to correct or amend as feasible, any Information that is found to be inaccurate or deficient.
WealthScore may withhold or may not be able to provide information that:
The User shall indemnify WealthScore and/or any of its officers and representatives from any cost, damage, liability or other consequence that may arise due to any act or omission of the User.
20. Modification of this privacy agreement
WealthScore reserves the right to change the terms and conditions under which WealthScore websites are offered.
21. Governing law and Jurisdiction
The privacy agreement shall be governed by and construed in accordance with the laws of India and shall be subject to the exclusive jurisdiction of the courts of Delhi, India.
22. Consent for Information
The User acknowledges that he has read and understood the content of this privacy agreement.
The User undertakes that once it has clicked “By clicking continue, you agree to our terms & conditions” appearing on our website the User shall be deemed to have given consent for the collection, storage, handling or dealing and usage of Information and have accepted this privacy agreement.