MyFi Privacy Policy

This document is an electronic record in terms of the Information Technology Act, 2000 and rules framed thereunder as applicable. This electronic record is generated by a computer system and does not require any physical or digital signatures.

MyFi Fintech Advisory Services Private Limited, operating under its trade name ‘MyFi’, (hereinafter referred to as “MyFi”) is the owner of the website with domain name https://askmyfi.com and MyFi platform (hereinafter referred to as the “MyFi Platform”).

MyFi is concerned about the privacy of the Users who access, browse, use and transmit content on the MyFi Platform. This Privacy Policy is for the purpose of acquainting the Users with the manner in which MyFi collects, uses and discloses the Users’ information collected through the MyFi Platform.

Please read the following terms of MyFi Privacy Policy:

DEFINITIONS:

“We”, “Us”, “Our”, “Company” shall refer to MyFi Fintech Advisory Services Private Limited.

“You”, “Yours”, “Yourself”, “User”, “MyFi User” refers to any individual, non- individual or corporate body.

Cookie shall mean a small text file that is stored on the User’s computer that will enable MyFi to recognize the User when the User visits the MyFi Platform. A cookie also enables MyFi to store the User’s preferences and settings, enhance the User’s experience by delivering content and advertising suited to the User’s interests, perform research and analytics, track usage and activity on the MyFi Platform, and assist with security and administrative functions.

Force Majeure Event shall mean any event that is beyond the reasonable control of MyFi and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.

Personally Identifiable Information shall mean the data or information that is personal to a User and allows persons other than the User to identify the User personally from such data or information; information that personally identifies or can be used to identify, contact or locate the person, to whom such information belongs including, including without limitation, log in name, email address, Facebook account details, Google account details, password and location details which will likely be collected at the time of User’s registration on the MyFi Platform.

Pixel Tag / Web Beacon / Clear GIF shall mean a tiny graphic with a unique identifier, embedded invisibly on a webpage (or an online ad or email), and is used to count or track things like activity on a webpage or ad impressions or clicks, as well as to access cookies stored on Users’ computers or other devices.

Privacy Policy shall mean this Privacy Policy.

User(s) shall mean any person who accesses or avails the MyFi Platform for the purpose of browsing, viewing, creating, posting, publishing, hosting, displaying, sharing, uploading or otherwise transmitting its content on the MyFi Platform.

Capitalized words used in the Privacy Policy shall have the meaning ascribed to them in the Terms and Conditions of Use.

GENERAL TERMS:

The User hereby acknowledges and agrees that the Privacy Policy is subject to changes without express and specific intimation and the Users shall be required to review the Privacy Policy regularly. The continued use of the MyFi Platform expresses the User’s consent to the updated Privacy Policy.

The protection and security of the User’s Personally Identifiable Information is one of MyFi’s foremost concerns. The Privacy Policy discloses MyFi’s practice with respect to the information collected from the User on the MyFi Platform.

By using the MyFi Platform the User agrees to accept the terms of the Privacy Policy as well as MyFi’s Terms and Conditions available at https://info.askmyfi.com/terms as provided for at Privacy Policy. By accessing or using the MyFi Platform, the User expressly consents to MyFi’s use and disclosure of the Users’ personal information in the manner described in this Privacy Policy.

The Users are hereby informed that in accordance with the Information Technology (Intermediary Guidelines) Rules, 2011, in case of any non-compliance with the Terms & Conditions and the Privacy Policy, MyFi reserves its right to immediately terminate access or usage rights of the Users.

By using the MyFi Platform, the User agrees to the terms of this Privacy Policy. If the User does not agree with the terms of the Privacy Policy, the User is requested to stop from proceeding further and to cease using the MyFi Platform.

The Privacy Policy shall at all times be read along with the Terms & Conditions of the MyFi Platform. Unless stated otherwise, the Privacy Policy applies to all information that MyFi has about the User and User’s account.

COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION AND OTHER INFORMATION / DATA:

In order to enable a User to have access to the features, benefits or use of the MyFi Platform Services on the MyFi Platform, the User may require to provide certain information on the MyFi Platform which may constitute ‘personal information’ or ‘sensitive personal data or information’ of a person which shall be governed under regulation 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive personal information) Rules, 2011, along with other relevant data privacy laws of the land and Prevention of Money Laundering Act (PMLA) 2002.

We may collect the following categories of personal information or sensitive personal data or information from the User but not limited to:

On boarding / Registration:

  • Name, DOB, Gender, Nationality, Father’s name, Mother’s name, Marital status, photo;

  • Address, ZIP/postal code, location, phone number, e-mail id, your contacts and nominee details;

  • Bank account number, your name on bank passbook and IFSC code of the bank;

  • PAN card number, Aadhar card number (redacted), KYC related information either through videos or other online / offline verification documents as per the mandate from banking / financial institutions offering the financial product, regulatory guidelines or to comply with such other directions of relevant regulatory authorities, for the MyFi Platform Services you shall be utilizing (purpose of investments & transactions) and your business-related information;

  • Employment related details (e.g. occupation, income, employer details, designation) as part of our record retention for Central KYC Records Registry (CKYCR) purposes under Prevention of Money Laundering (Maintenance of Records) Rules, 2005;

  • Information in relation to Your device while using our Platform (basis Your consent) like communication information including contacts and call logs, device camera access, device microphone access, device information (including storage, model, mobile network information, device type, IP Address and location, device unique identifier) which might be necessary for location based services, KYC requirement, fraud prevention, security and compliance requirement, technical and operational usage etc.;

  • For certain financial services offered by our partner(s), to comply with regulatory direction(s) and for security purpose(s), we may request our Users to permit us to link their mobile device(s), and SIM with their account for device binding purpose. We ensure that User(s) prior and explicit permission is sought, to perform device binding by pushing SMS through your device. Post verification, User’s device will become registered device. In case of change of device, User will be required to re-login and re-authorize itself on its device;

  • Browser plug-ins, and cookies or similar technologies that may identify your browser Application and plug-ins, notifications etc.

KYC Details:

  • To comply with regulatory requirements, based on Your explicit consent we fetch Your KYC (Know Your Customer) details from regulated KYC Registry such as CKYC, CVL etc.

Credit Score and Liabilities Information:

You provide explicit consent to Us for the following:

  • Collect credit related information from third party service provider that are expressly authorised by You to distribute such information (for example, Experian or CRIF High Mark which is a credit information company registered under the Credit Information Companies (Regulation) Act, 2005);

  • giving an access to Your email is sought to provide a holistic view of your credit card account details such as total amount due, minimum amount due and due date statements from the applicable services, any other financial & transactional details, curated rewards and offers etc.

  • We shall securely store account details for each of Your credit card accounts, including your sign-in username and authorisation tokens for tracked accounts. This information will be used to enable Us to automatically access Your applicable credit card statements to analyze, extract, and store information securely from such accounts for use in the Application

Investment Information:

  • Upload your investment statements in PDF or Excel versions:

    • These are investment statements that you get from depositories or brokers or Registrar & Transfer Agents such as Computer Age Management Services, Karvy Fintech Private Limited, National Securities Depositories Limited, Central Depositories Services Limited, etc.

    • You provide explicit consent to MyFi Platform to fetch these statements from third party service providers;

  • You provide investment details like scheme name, investment type, investment date and investment value by manually entering the data whenever necessary / applicable.

Email Accounts:

You can also choose to integrate one or more of email accounts by connecting such account(s) with Your account on the MyFi Platform. The following are the information collected from Your consented email accounts:

  • The attachments from the senders who have the details of your financials investments or spends such as folio numbers, transaction dates, Redemption Amounts, income tax document like ITR, your credit card, statements, spends. MyFi organizes this information in your account to provide deep analytics and other services.

  • We access your email account(s), only basis your explicit consent for auto tracking your investments & spends in order to effectively help you in organizing your financial life. We will only be accessing and analyzing the contents of email(s) (including the attachments) consisting of ‘read-only’ in a secured manner. You can choose to grant your explicit consent to connect your email account(s) with MyFi account.

  • The benefit of opting to connect Your Gmail account is that your both investment and expense information gets updated automatically every month. Given the updated information, the application can hence give you deep and accurate analytics on your net worth and to curate best offers for you to avail various financial products / services via our Platform.

  • You can anytime choose to de-link your email account with the application at any time and/ or you can delete your information by writing to privacy@askmyfi.com.

  • Please note that such data obtained by this integration will be used by the Company solely for providing MyFi Platform Services and for improving the User experience pertaining to the features of the Platform.

  • We encourage the User to review the information prior to giving consent for integration of the email address with the account on the Platform. The User may at any time opt to de-link the email address connected with the account opened on MyFi Platform and/or delete the information by writing to privacy@askmyfi.com.

MyFi shall not be responsible for the authenticity of the information provided by the User.

RACKING OF INFORMATION:

MyFi may use Cookies, Pixel Tags, Web Beacons, flash cookies and similar files or technologies to collect, track and store information based on the User’s use of the MyFi Platform. MyFi uses Pixel Tags to measure the popularity of pages, people and hashtags. MyFi may use Web Beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics.

Most browsers are set to automatically allow Cookies. Please note it may be possible to disable some (but not all) Cookies through the browser settings on the User’s electronic device, but doing so may interfere with certain functionality on the MyFi Platform. Major browsers provide the Users with various options when it comes to Cookies. The Users can usually set their browsers to block all third-party Cookies (which are those set by third-party companies collecting information on Websites operated by other companies), block all Cookies (including first-party Cookies such as the ones MyFi uses to collect search activity information about its Users), or block specific Cookies.

To modify the Cookie settings on the MyFi Platform, please visit the browser’s help settings. Flash cookies operate differently than browser Cookies and cannot be removed or blocked via web browser settings. By using the MyFi Platform the Users are set to accept Cookies and consent to MyFi’s use of Cookies in the manner described in this section.

MyFi shall have no control over the usage of any third party cookies placed on the MyFi Platform.

COLLECTION AND USE OF NON-PERSONAL DATA:

Non-personal data is data that can never be used to identify an individual. We may collect information regarding customer activities on MyFi Platform. This aggregated information shall be used by Us in research, analysis, to improve and monitor Our services and for various promotional schemes and offers. Such non personal data may be shared in aggregated, non-personal form with third party to enhance customer experience, offerings or services. MyFi Platform uses cookies, and while using the Platform You will be prompted to accept all cookies. We may place text files in the browser files of Your computer system.

SHARING OF INFORMATION:

MyFi shall use the information collected from the User to verify the identity of the User, to contact Users, for purposes of use of the MyFi Platform and for any other purpose with the consent of the User.

MyFi will share some or all of the User’s Personally Identifiable Information with another business entity in the event such business entity merges with MyFi, acquires MyFi or enters into any other corporate restructuring. Such business entity shall be required to comply with this Privacy Policy with respect to the User’s Personally Identifiable Information.

MyFi shall disclose the Personally Identifiable Information without requiring any prior consent from the Users where such disclosure is required to be made to a government agency mandated under the law to obtain such Personally Identifiable Information. MyFi shall be required to make such disclosures to government agencies in all such cases for the prevention, detection, and investigation of fraud including cyber related crimes.

MyFi shall be compelled to disclose the Personally Identifiable information of the Users to a third party in all such cases where MyFi is acting in compliance of an order passed under law, directing MyFi to disclose such Personally identifiable Information.

ASSESSING, REVIEWING AND CHANGING PERSONAL INFORMATION:

MyFi will take reasonable steps to accurately record the personal information that the User provides to MyFi and any subsequent updates.

MyFi encourages the User to review, update and correct the information that MyFi maintains about the User on the MyFi Platform. Upon the User’s request, MyFi will delete any such information that is inaccurate, incomplete, or irrelevant for legitimate purposes, or is being processed in a way, which infringes any applicable legal requirement.

RETENTION PERIOD:

We do not keep your personal data and information longer than necessary for the purpose of the processing except for any record retention required by applicable laws, including but not limited to Securities and Exchange Board of India (Investment Advisers) Regulations 2013, Insurance Regulatory Development Authority of India (Registration of Corporate Agents) Regulations 2015 and Prevention of Money Laundering Act 2002. This includes, for example, the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to carry out legal work, for the establishment or defence of legal claims. We may aggregate and anonymize your personal data and information (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you. In the event you delete your account, we will delete all data and information relating to your account (subject to certain data we are required to retain as per applicable law) within 90 (ninety) days from the date you request for such deletion by either writing to us or by executing deletion via MyFi mobile application.

SECURITY PRECAUTIONS:

MyFi has implemented appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access to the information of the User and to maintain data security. These safeguards take into account the sensitivity of the information that MyFi collects, process and stores and the current state of technology.

MyFi follows generally accepted industry standards to protect the information submitted to it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while MyFi strives to use commercially acceptable means to protect the information of the Users, MyFi cannot guarantee its absolute security and thereby usage in a manner that is inconsistent with the Privacy Policy.

MyFi assumes no liability or responsibility for disclosure of the User’s information due to errors in transmission, unauthorized third-party access, or other causes beyond MyFi’s control. The User plays an important role in keeping its information secure. The User should not share its account information with anyone. If MyFi receives instructions through the User’s account and password, MyFi will consider that such User has authorized the instructions.

Notwithstanding anything contained in the Privacy Policy or elsewhere, MyFi shall not be held responsible for any loss, damage or misuse of the User’s personal information, if such loss, damage or misuse is attributable to a Force Majeure Event.

CHANGES TO THE PRIVACY POLICY:

MyFi reserves the right to amend the Privacy Policy from time to time to reflect changes in the Applicable Law, MyFi’s data collection and use practices, the features of the MyFi Platform or advances in technology.

The User is requested to check this page periodically for changes. Use of information collected by MyFi is subject to the Privacy Policy in effect at the time such information is used. If MyFi makes any material changes to the Privacy Policy, MyFi will post the changes on the MyFi Platform. The User is requested to review the changes carefully.

The User’s continued use of the MyFi Platform following the posting of changes to the Privacy Policy will constitute the User’s consent and acceptance of those changes.

GOVERNING LAW & DISPUTE:

The law governing the Terms shall be the substantive laws of the Republic of India, without giving effect to the conflicts of law principles of any jurisdiction.

Any dispute arising out of or in connection with the Terms and/or the licence, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration by a sole arbitrator to be appointed by MyFi in accordance with the Arbitration Rules of the Mumbai Centre for International Arbitration (‘MCIA’), which rules are deemed to be incorporated by reference in this clause. The seat and venue of the arbitration shall be Bangalore, India.

DISCLAIMER OF INFORMATION:

We do not control or endorse the content, messages or information placed on MyFi Platform by any user or third party and, therefore, We specifically disclaim any liability with regard to such information and Your interaction / engagement with such users, third party providers and products or services offered by them and You agree that you waive any claims against Us relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Us relating to the same.

You are responsible for maintaining the accuracy, truthfulness, correctness and completeness of the information You submit or provide to Us, on the Platform; and shall hold harmless and indemnify Us from and against all claims arising out of or in relation to the wrongful information posted, provided by You to Us, on the Platform. If Your personal information changes, You may correct, delete inaccuracies, or amend information by making the change on Our member information page or by contacting Us on the contact information given below. There may be circumstances where We will not correct, delete or update Your personal data information, including; (i) where the personal data and information is opinion data that is kept solely for evaluative purpose; and (ii) the personal data information is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed. If you wish to cancel your account or request that We no longer use your information to provide you Services, you may contact us on the contact information given below.

GRIEVANCE OFFICER:

In accordance with the provisions of the Information Technology Act, 2000, and rules made thereunder, the name and contact details of the Grievance Officer are provided below:

Attn: Mr. Kiran Nambiar

Designation: Grievance Officer

Email: grievance@askmyfi.com

Time: Mon - Friday (10 AM - 7 PM)

Address: 601, Pinnacle House 6th Floor, TPS III, P. D. Hinduja Road, Bandra West, Mumbai – 400050, Maharashtra, India

Last updated on 20th March 2024

Last updated