Privacy Policy

This Privacy Policy ("Privacy Policy") forms an integral part of the Terms of Use governing the access and use of the Application and the services made available through it ("Services"). By accessing or using the Application, you acknowledge that you have read, understood, and agreed to the collection, use, processing, storage, disclosure, and protection of your personal data in accordance with this Privacy Policy and the Terms of Use.

If you do not agree with this Privacy Policy or the Terms of Use, you should immediately discontinue the use of the Application and refrain from creating or operating an account.

We are committed to protecting your privacy and maintaining the confidentiality, integrity, and security of the information entrusted to us. This Privacy Policy explains how we collect, use, process, store, disclose, and safeguard your information in accordance with applicable laws.

Scope of this privacy policy

This Privacy Policy applies to all individuals who access or use the Application or otherwise interact with us through any electronic or offline mode in connection with our Services.

All visitors to our Website at
https://www.simplicityinvesting.com

All registered users and account holders

All individuals who contact us, subscribe to our communications, or engage with our services.

This Privacy Policy governs:

Collection of personal and non-personal information

Disclosure and sharing of information

Processing and use of such information

Data retention practices

Security measures implemented by us; and

Your rights relating to your personal data.

1. Introduction

Simplicity Investing India Pvt. Ltd. ("Company", "we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard your personal data when you visit our website at https://www.simplicityinvesting.com ("Website") or use our services.

This Policy is prepared in compliance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), and the Digital Personal Data Protection Act, 2023 ("DPDPA"), as applicable.

By using the Website, you consent to the data practices described in this Privacy Policy. If you do not agree with this Policy, please do not access or use our Website.

2. Identity of the Data Fiduciary / Data Controller

For the purposes of the DPDPA and applicable data protection laws, the Data Fiduciary (controller of your personal data) is:

Simplicity Investing India Pvt. Ltd.

https://www.simplicityinvesting.com

info@simplicityinvesting.com

3. Information We Collect

3.1 Information You Provide to Us

We collect personal data that you voluntarily provide, including:
Identity Data: Full name, date of birth, PAN (Permanent Account Number), Aadhaar number (where applicable), and other government-issued identification;
Contact Data: Email address, phone number, postal/registered address;
Account Data: Username, password, account preferences, and profile information;
Financial Data: Bank account details, investment preferences, risk profile, credit data and income information;
Transaction Data: Records of transactions, service requests, and correspondence;
Communication Data: Messages, queries, feedback, and complaints .
Income information, employment details and financial profile;
Assets, liabilities, investments, insurance information
Family details;
Investment preferences, financial goals and risk assessment information;
Communication records and customer support interactions; and
Any other information voluntarily provided by you while using our Services.

3.2 Information Collected Automatically

When you access our Website or applications, we automatically collect certain technical information:
Usage Data: Pages visited, time spent, links clicked, and navigation paths;
Device Data: IP address, browser type and version, operating system, device identifiers;
Log Files: Server logs recording date/time, referring URL, and ISP information;
Such information is used to improve the functionality, security and performance of the Application.

Cookies and Similar Technologies

We may use cookies, pixels, web beacons and similar technologies to enhance your experience, remember your preferences, analyse user behaviour and improve our Services.

You may configure your browser or device settings to decline cookies; however, certain features of the Application may not function properly if cookies are disabled.

3.3 Sensitive Personal Data or Information (SPDI)

We may collect Sensitive Personal Data as defined under the SPDI Rules, including financial information and authentication credentials. Such data is collected only with your explicit consent and is handled with heightened security measures. We do not collect SPDI unless it is necessary for a legitimate, specific, and disclosed purpose.

3.4 Information from Third Parties

We may receive information about you from:
KYC (Know Your Customer) verification agencies;
Credit bureaus and financial data aggregators;
SEBI-registered entities and regulated market intermediaries;
Social login providers (e.g., Google, LinkedIn) if you choose to authenticate via these platforms.

4. Legal Basis for Processing

We process your personal data on the following legal grounds:
Consent: Where you have given explicit, free, and informed consent for a specific purpose;
Contractual Necessity: Where processing is required to fulfil a contract with you or to take steps at your request prior to entering into a contract;
Legal Obligation: Where we are required to process data to comply with applicable law (e.g., PMLA, SEBI regulations, Income Tax Act);
Legitimate Interests: Where processing is in our legitimate business interests and does not override your rights and interests;
Vital Interests: In rare cases, where necessary to protect your vital interests.

5. How We Use Your Personal Data

We use the personal data we collect for the following purposes:
To create and manage your account and deliver our services;
To provide investment-related tools, research, market data, and educational content;
To process transactions and send service-related communications;
To verify your identity and conduct KYC/AML (Anti-Money Laundering) checks as required by law;
To personalise your experience and improve the relevance of content;
To communicate with you about updates, offers, service related, newsletters, and promotional material (with your consent);
To comply with legal obligations, regulatory requirements, and court orders;
To detect, prevent, and investigate fraud, security incidents, and other illegal activity;
To analyse usage patterns and improve our Website, products, and services;
To enforce our Terms and Conditions and other legal agreements.
To provide financial planning, investment advisory and other Services;
To understand your financial profile and generate personalized recommendations;
To provide customer support;
To conduct internal audits, analytics and risk assessments;
To protect our rights, users and business interests.

6. Disclosure of Your Personal Data

We value the confidentiality of your personal information and will not sell your personal data. However, we may disclose or share your information in the following circumstances:

6.1 Internal Sharing

Your data may be shared within the Company on a need-to-know basis among employees and teams responsible for delivering our services.

6.2 Third-Party Service Providers

We may share your data with trusted third-party vendors who perform services on our behalf, including:
KYC and identity verification providers;
Payment processors and banking partners;
Cloud hosting and IT infrastructure providers;
Analytics and market data providers;
Email and communication service providers;
Legal, accounting, and compliance advisors.
Other consultants
All such third parties are contractually bound to process your data only as instructed and to maintain appropriate security measures.

6.3 Regulatory & Legal Disclosure

We may disclose information to regulators, statutory authorities, governmental agencies, courts, law enforcement authorities or other competent bodies where required by applicable law or legal process.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the successor entity, subject to equivalent data protection obligations.

6.5 No Sale of Personal Data

Simplicity Investing India Pvt. Ltd. does not sell, rent, trade, or lease your personal data to third parties for marketing purposes. Any future advertising partnerships will be disclosed, and your consent will be sought where required.

7. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy or for such longer period as may be required under applicable laws, regulatory requirements, contractual obligations, dispute resolution requirements or enforcement of legal rights.

Upon expiry of the applicable retention period, the information will be securely deleted, anonymized or archived in accordance with applicable law.

8. Cookies & Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help the website recognise your device, remember your preferences, and improve your experience.

8.2 Types of Cookies We Use

Strictly Necessary Cookies: Essential for the Website to function and cannot be disabled.
Performance/Analytics Cookies: Help us understand how visitors use the Website (e.g., Google Analytics).
Functional Cookies: Remember your preferences and settings.
Targeting/Advertising Cookies: Used to deliver relevant advertisements (only if advertising partners are engaged; we will update this policy accordingly).

8.3 Web Beacons

We may use web beacons (also called pixel tags or clear GIFs) in our emails and on the Website to track engagement and improve our communications.

8.4 Managing Cookies

You may disable or manage cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Website. For browser-specific instructions, please visit the help section of your browser.

9. Data Security

Simplicity Investing India Pvt. Ltd. implements reasonable security practices and procedures as mandated by the SPDI Rules and the DPDPA, including:
SSL/TLS encryption for data in transit;
Encrypted storage of sensitive data;
Role-based access controls and multi-factor authentication for internal systems;
Regular security audits, vulnerability assessments, and penetration testing;
Employee training on data protection and confidentiality obligations;
Incident response procedures for data breaches.
While we strive to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. In the event of a data breach that poses a risk to your rights and interests, we will notify you and the appropriate authorities in accordance with applicable law.

10. Cross-Border Data Transfers

Our primary operations and data storage are located within India. Where it becomes necessary to transfer your personal data outside India (for example, to cloud service providers), we will ensure such transfers comply with applicable Indian law, including any adequacy decisions or standard contractual clauses as prescribed under the DPDPA.

11. Your Data Protection Rights

Under applicable Indian law, including the DPDPA and SPDI Rules, you have the following rights:
Right to Access: You may request a copy of the personal data we hold about you.
Right to Correction: You may request correction of inaccurate or incomplete data.
Right to Erasure: You may request deletion of your personal data, subject to legal retention obligations.
Right to Withdraw Consent: You may withdraw consent at any time; however, this will not affect processing already carried out on the basis of prior consent.
Right to Grievance Redressal: You have the right to register a grievance with our Grievance Officer and receive a timely response.
Right to Nominate: Under the DPDPA, you may nominate another individual to exercise your rights in the event of your death or incapacity.
To exercise any of these rights, please contact our Grievance Officer at info@simplicityinvesting.com We will respond to your request within 30 (thirty) days of receipt.

12. Children's Privacy

The Website is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected personal data from a person under 18, we will take immediate steps to delete such data. If you believe a minor has submitted personal data to us, please contact us immediately at info@simplicityinvesting.com

13. Advertising & Third-Party Partners

At present, Simplicity Investing India Pvt. Ltd. does not have any active advertising partners, and no third-party advertising cookies are deployed on the Website. Should advertising partnerships be established in the future, this Privacy Policy will be updated to reflect:
The identity of such advertising partners;
The types of data shared or accessible to such partners;
Your opt-out rights with respect to targeted advertising.
Third-party partners, if engaged, will be required to comply with applicable data protection laws and our data sharing agreements.

14. Third-Party Websites

Our Website may contain links to third-party websites. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of all third-party websites you visit. Simplicity Investing India Pvt. Ltd. is not responsible for the content or privacy practices of any third-party sites.

15. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. When we make material changes, we will update this document and, where appropriate, notify you through a prominent notice on the Website.

Your continued use of the Website following the posting of changes constitutes your acceptance of those changes. We encourage you to review this Policy periodically.

16. Governing Law

This Privacy Policy is governed by the laws of India. Any disputes arising in connection with this Policy shall be subject to the exclusive jurisdiction of the courts in [Pune, Maharashtra], India.