WealthDesk is a platform that lets you invest in systematic, modern investment products called WealthBasket.
Terms & Conditions
Last updated: 03/05/2021
1.1. Wealth Technology & Services Private Limited (“WealthDesk”) is a private limited company which offers a proprietary and technology platform at www.wealthdesk.in and also over microsites created therefrom (including microsites created on third-party websites) (jointly “the WealthDesk Platform”). The WealthDesk Platform is a set of proprietary APIs, SDKs, tools, plugins, code, technology, content, and services that enables stock brokers, investment advisors, research analysts and investors to transact in WealthBaskets over WealthDesk’s digital platforms (website or mobile app) or digital platforms of third-parties which are powered by the WealthDesk Platform. A WealthBasket is a selection of Securities in a particular combination that is created and managed by SEBI-registered investment advisors and/or SEBI-registered research analysts which allow you to place purchase orders for such offering through SEBI-registered stock brokers who are registered with the WealthDesk Platform.
1.3. By accepting the provision of these Terms, you represent to WealthDesk that you are a person ‘competent to contract’ under the Indian Contract Act, 1872 and are not disqualified by operation of law, order of a court or an executive authority, or by provisions of any contract to which you are bound, from accessing and using the WealthDesk Platform and from performing your obligations hereunder. WealthDesk reserves the right to take suitable action in case this representation is found to have been incorrect.
2. REGISTRATION AND ACCESS
2.1. The WealthDesk Platform allows you to create a user account. You may browse the WealthDesk Platform without creating a user account. However, some of the features of the WealthDesk Platform may be unavailable to you unless you create such account. You should not create more than one user account on the WealthDesk Platform. At the time of creating your user account, you will be required to submit certain information about yourself. It is recommended that you keep your account information current and to follow good password security practices to avoid misuse of your profile. You are solely responsible for the security of your account; you expressly agree to absolve the Company of any responsibility and liability in this regard.
2.2. All information that you provide to us during the process of your registration and thereafter should be accurate and complete. WealthDesk is not responsible to verify the information that you provide. However, WealthDesk may require you to substantiate the information provided by you through supporting documents, without being obligated to do so.
2.3. You shall be solely responsible for maintaining the confidentiality of your user account and its access credentials. You shall notify WealthDesk immediately in writing of any unauthorised access of or through your user account or any other breach of security. Notwithstanding such notification, WealthDesk will not be liable for any loss that may be incurred by you as a result of unauthorised access.
2.4. WealthDesk may, at its sole discretion, curtail your access to the WealthDesk Platform without the need to assign a reason if:
- (a) You are in breach of any provisions of these Terms;
- (b) WealthDesk is unable to verify or authenticate any information provided by you; or
- (c) WealthDesk has reason to believe that your actions may infringe on any third-party rights, breach any applicable law, or violate any order of a court or an executive authority.
2.5. WealthDesk reserves the right, at its sole discretion, to withhold, suspend or to terminate your access to the WealthDesk Platform without prior notice for any reasonable cause, including routine maintenance activity, breach of the provisions of this Terms by you, and audit and fraud detection activity.
2.6. If your access has been curtailed, withheld, suspended to terminated, then you shall not attempt to re-register yourself on the WealthDesk Platform or to use the WealthDesk Platform in any manner whatsoever.
2.7. The remedies available to WealthDesk hereunder are without prejudice to its entitlements under the law, including the right to recover any amount due to be paid by you and to pursue such legal action as may be deemed necessary by WealthDesk.
3. INTELLECTUAL PROPERTY AND LICENSE THERETO
3.1. WealthDesk (and its licensors, where applicable) own all right, title and interest, including all related intellectual property rights, in and to the content featured on the WealthDesk Platform, the service rendered thereby, and in any suggestions, ideas, enhancement requests, feedback, recommendations or other information provided by you or any other party to WealthDesk. You shall not create, prepare, distribute, exchange, copy, adapt, modify, sell, transmit, publicly display, publicly perform, broadcast any work which is a derivative of or which is based upon such intellectual property.
3.2. This Agreement is not a sale and does not convey to you any rights of ownership in or related to the WealthDesk Platform or the intellectual property rights owned by WealthDesk or by its licensors. The WealthDesk name, the WealthDesk logo, and the names associated with the WealthDesk Platform are trademarks of WealthDesk and other third parties, and no right or license is granted to you use them.
3.3. Any personal information or details belonging to you and provided by you while availing or accessing the WealthDesk Platform, belong solely to you.
3.4. In consideration of your acceptance and continuing compliance with the provisions of these Terms, WealthDesk grants you a restricted, revocable, non-exclusive, non-transferable license (“License”) to access and use the WealthDesk Platform. The License is revocable without requiring prior notice.
3.5. If you involve in any of the following activities, then without prejudice to any of the rights of WealthDesk under the law, the License shall automatically revoke without any forenotice.
- (d) breach of the provisions of these Terms by you;
- (e) violation of any law or regulation or any order of a court or an executive authority;
- (f) use by you of manual or automated software, devices, scripts robots, other means or processes to access, “scrape,” “crawl” or “spider” any web pages or other assets of or related to the WealthDesk Platform;
- (g) use by you of the WealthDesk Platform for any purpose that is not expressly permitted by these Terms;
- (h) copying, storage or otherwise accessing of any information contained on or related to the WealthDesk Platform by you for purposes not expressly permitted by these Terms;
- (i) infringement by you of the rights of any person or entity, including without limitation, intellectual property rights, privacy rights, publicity rights or contractual rights;
- (j) interference by you with the working of or to adversely affect the WealthDesk Platform, including, without limitation, through the use of viruses, cancel bots, trojans, harmful code, flood pings, denial-of-service attacks, packet or IP spoofing, forged routing or electronic mail address information or similar methods or technology;
- (k) use by you of the WealthDesk Platform to transmit, distribute, post or submit any information that may be immoral, illegal or otherwise undesirable;
- (l) immoral, illegal or otherwise undesirable conduct exhibited by you in respect of the WealthDesk Platform any person or entity associated therewith;
- (m) registration for more than one user account by you or registration of a user account on behalf of another person without express permission of such person;
- (n) impersonate any person or entity, or falsify or otherwise misrepresent yourself or your affiliation or non-affiliation with any person or entity, or otherwise post any reviews that exhibit a conflict of interest;
- (o) an attempt by you to (i) probe, scan or test the vulnerability of the WealthDesk Platform, (ii) breach any security or authentication measures, (iii) decipher, decompile, disassemble or reverse engineer any of the software used to provide the services, products or content;
- (p) advocating, encouraging, or assisting any third-party in doing any of the foregoing.
4.1. You acknowledge and agree that the WealthDesk Platform is provided “as is,” and “as available” basis, without warranty of any kind, either express or implied to the maximum extent permitted by applicable laws. WealthDesk expressly disclaims any and all other promises, representations and warranties, whether express or implied, including, but not limited to, any implied warranties of merchantability, fitness for a particular purpose, quiet enjoyment, system integration and/or data accuracy in connection with use of the WealthDesk Platform. WealthDesk does not warrant that the WealthDesk Platform, any application service or any other services provided by WealthDesk will meet your requirements or that the operation of the WealthDesk Platform, any application service or any other services will be uninterrupted or error-free, or that all errors will be corrected. WealthDesk make no warranty regarding the quality of the WealthDesk Platform, services, content or product or the accuracy, your inability to use the WealthDesk Platform, or the timeliness, truthfulness, completeness or reliability of any information obtained the WealthDesk Platform.
4.2. No advice or information, whether oral or written, obtained from WealthDesk or through the WealthDesk Platform creates any warranty not expressly made herein. You are solely responsible for all of your communications and interactions with any third-party with whom you communicate or interact as a result of your use of the WealthDesk Platform, including, but not limited to, stock brokers, investment advisors, research analyst, vendors, service providers, among others. WealthDesk makes no representations or warranties as the conduct or quality of services rendered by such third-parties.
4.3. WealthDesk expressly disclaims any liability in respect of any of the above matters.
5. LIMITATION OF LIABILITY
5.1. You acknowledge and agree that, to the maximum extent permitted by law, the entire risk, damages and losses arising out of your access to the WealthDesk Platform and content available thereon, any contact you have with any other third-party operators, brokers, investment advisors, research analyst, vendors, service providers, among others, whether in person or online remains with you. Neither WealthDesk nor any of its employees, representatives, agents, sub-contractors, licensors involved in creating, producing, or operating the WealthDesk Platform and content thereon, will be liable for any incidental, special, exemplary or consequential damages, including theft, delay or non-performance, server error, lost profits, loss of data or loss of goodwill, service interruption, computer damage or system failure or the cost of substitute products or services, or for any damages for personal or bodily injury or emotional distress arising out of or in connection with your use of the WealthDesk Platform or content therein, or inability to use the WealthDesk Platform or content thereon, from any communications, interactions or meetings with any third-party operators, brokers, advisors, research analyst, vendors, service providers, among others whether in person or online or other persons with whom you may communicate or interact as a result of your use of the WealthDesk Platform, whether based on warranty, contract, law, tort (including negligence), product, content or service liability irrespective of whether or not we have been informed of the possibility of such damage, even if a limited remedy set forth herein is found to have failed of its essential purpose.
5.3. Notwithstanding any provision to the contrary, in respect of any loss or claims arising due to any deficiency or delay in use of the WealthDesk Platform, your exclusive remedy and the entire liability of WealthDesk shall be the correction of such deficiency or delay on a going forward basis.
5.4. You acknowledge and understand that the disclaimers, exclusions and limitations of liability set forth in herein form an essential basis of the contract between you and WealthDesk, that WealthDesk has relied upon your acceptance of such disclaimers, exclusions and limitations of liability while agreeing to the provisions of these Terms, and that absent such disclaimers, exclusions and limitations of liability, the agreement constituted hereby would not have been consented to by WealthDesk.
5.5. The provisions of this clause shall survive the termination of the agreement constituted hereby.
6.1. You acknowledge and agree to release, defend, indemnify, and hold WealthDesk and its affiliates and subsidiaries, officers, directors, employees, contractors, sub-contractors and agents, harmless from and against any claims including third-party claims, liabilities, damages, losses, and expenses, including, without limitation, legal fees, arising out of or in any way connected with the access or use of the WealthDesk Platform or content therein by you or any persons or representatives on your behalf.
6.2. WealthDesk acknowledges and agrees to defend, indemnify, and hold you harmless from and against any third-party claims arising out of infringement of any third-party intellectual properties in respect of the WealthDesk Platform (“Infringement Claims”) if you provide WealthDesk with prior written notice of such third-party claims and you give WealthDesk the control to defend and settle any claim as per its discretion. WealthDesk shall allow your legal representative to defend you, provided the control of the entire case regarding the claim remains with WealthDesk.
7. FURTHER TERMS
7.1. WealthDesk reserves the right to amend these Terms at its discretion, without the need to provide prior notice to you. You can review the most current version of these Terms at any time by visiting this webpage. It is your responsibility to check this webpage periodically for changes. If you do not agree with any of the contents of these Terms, you must immediately cease your access and use of the WealthDesk Platform. By continuing to use or access the WealthDesk Platform, you confirm that you have read, understood and accepted each of the provisions of these Terms.
7.2. If WealthDesk cannot perform its obligations hereunder due to an act of God such as a pandemic, an epidemic, government decisions, labour unrest, insolvency, business exigencies, operational and technical issues, international events, change in climate, change in laws, terrorist activity, refusal or delay in performance by third-party service providers, technological issues, server failures, or any other reason beyond the control of WealthDesk, then WealthDesk will be excused from such performance to the extent of such prevention, restriction or interference for the period that it persists.
7.3. You or anyone acting on your behalf, will not directly or indirectly, disparage or denigrate or encourage others to disparage or denigrate WealthDesk or the WealthDesk Platform. You shall not do any act which would adversely affect WealthDesk, the conduct of its business, or its business reputation. For purposes of this provision, the term “disparage” includes without limitation a) any comments or statements or inputs orally or in writing made in any matter or medium in the press or the media whether digital or otherwise or any other social networking sites; b) any publications, post, or otherwise release of any material in written, oral or electronic format; c) any speeches, interviews, or public statements that mentions us, our operations, clients, employees, products, or services with or without our prior written consent.
7.4. You or anyone on your behalf, will not, directly or indirectly solicit, encourage, facilitate, hire, engage, employ, coerce or induce any of our prospects, vendors, advertisers, agents, sales representatives, employees, contractors, consultants, service-providers, or licensees, to curtail their business relationship with WealthDesk. This excludes recruitments conducted pursuant to a non-targeted, general campaign.
7.5. Nothing contained these Terms constitute a relationship akin to a partnership or joint venture between you and WealthDesk or constitute one of them to be a representative or an agent of the other.
7.6. No third-party shall be entitled to make a claim under these Terms against WealthDesk.
7.7. If a court finds any provision of these Terms, or portion thereof to be unenforceable, then (a) the remainder of this Agreement shall continue in full force and effect, and (b) the impugned provision will be modified to the least extent possible so as to render it enforceable. The invalidity or unenforceability of any provisions of this Agreement in any jurisdiction shall not affect the validity, legality or enforceability of this Agreement in any other jurisdiction.
7.8. WealthDesk reserves the right to modify the provisions of these Terms. Any changes made here will be reflected on this webpage. Your continual use of the WealthDesk Platform shall be considered as an acceptance of the amended Terms.
7.9. All disputes in connection with a provision of these Terms shall be resolved by arbitration as per the Indian Arbitration and Conciliation Act, 1996 (as amended). The arbitration shall be conducted in Mumbai in English by a sole arbitrator jointly appointed by you and WealthDesk. If you and WealthDesk are unable to decide on an arbitrator within thirty (30) days, then any of you and WealthDesk may apply to the Hon’ble Bombay High Court under section 11 of the Arbitration and Conciliation Act, 1996 for such appointment. The arbitral award shall be final and binding upon you and WealthDesk You irrevocably and unconditionally agree to the exclusive jurisdiction of the courts in Mumbai, India.
8. CONTACT DETAILS
8.1. The WealthDesk Platform, which includes this website www.wealthdesk.in, is owned and operated by Wealth Technology & Services Private Limited.
8.2. WealthDesk is registered in India under registration number U74999MH2016PTC281896, and its registered office address is: 3rd Floor, A 305, Rustomjee Central Park, Andheri-Kurla Road, Opp. Kanakia Wall Street, Andheri (East), Mumbai – 400059, Maharashtra, India
8.3. You can contact WealthDesk (a) by post: at its registered office address provided above; (b) by email: on email@example.com; (c) by telephone: on the contact number published on www.wealthdesk.in; (d) by Website: by using the contact form on https://wealthdesk.in/contact-us
This document contains the disclaimers that apply to an intended or actual transaction involving WealthBaskets. PLEASE READ THIS DOCUMENT CAREFULLY BEFORE TRANSACTING IN A WEALTHBASKET. If you have a disagreement with any part of this document, then you should not transact in WealthBaskets. By transacting in a WealthBasket, whether on the WealthDesk Platform or otherwise, you accept the disclaimers contained herein and confirm that the exclusions and limitations of liability set out in this document are reasonable.
This document has neither been approved nor disapproved by SEBI, nor has SEBI certified the accuracy or adequacy of the contents of this document.
Wealth Technology & Services Private Limited (“WealthDesk”) is a private limited company which offers a proprietary and technology platform at www.wealthdesk.in and also over microsites created therefrom (including microsites created on third-party websites and applications (jointly “the WealthDesk Platform”). The WealthDesk Platform is a set of proprietary APIs, SDKs, tools, plugins, code, technology, content, and services that enables stock brokers, investment advisors,
research analysts and investors to transact in WealthBaskets over WealthDesk’s digital platforms (website or mobile app) or digital platforms of third-parties which are powered by the WealthDesk Platform. A WealthBasket”
is a selection of Securities in a particular combination that is created and managed by SEBI-registered investment advisors and/or SEBI-registered research analysts which allow you to place purchase orders for such offering through SEBI-registered stock brokers who are registered with the WealthDesk Platform.
- WealthDesk is merely a technology platform and enables the creation and transaction in WealthBaskets. WealthDesk is not registered with the Securities and Exchange Board of India (SEBI).
- WealthDesk does not offer any investment advice. The facts and figures which appear in the context of a WealthBasket are not an advice to invest and are provided merely for the purpose of providing information on a best-effort basis. These should not
be considered as an inducement or solicitation to invest. Performance related information provided has not been verified by SEBI.
- WealthBasket states and affirms that not all financial products are suitable for all Investors. It is solely your responsibility as an Investor to understand, and make an independent assessment of the suitability and appropriateness of a WealthBasket.
REGARDING THE WEALTHDESK PLATFORM
- The intermediaries that are involved in the WealthDesk Platform viz., stock brokers, investment advisers, and research analysts are verified by WealthDesk to be registered with the SEBI at the time of their registration; however, WealthDesk does not monitor their good-standing on a periodic basis. Such intermediaries are responsible to ensure compliance with the terms of their registration and with the applicable laws; WealthDesk does not monitor such compliance. WealthDesk has neither the authority, nor the obligation, to enquire into the business affairs and the conduct of business of such intermediaries. You are advised to examine the terms of business of such intermediaries and to
evaluate the services offered by them before transacting with them.
- The WealthDesk Platform is not a trading terminal; the execution of the trade in WealthBaskets is performed by stock brokers on their online trading platform. In order to transact in a WealthBasket, you may be required to open a trading and/or a demat account with the concerned stock broker if you do not have such an account.
- Based on the data available to WealthDesk, it may publish fact-based views and opinions regarding, inter alia, WealthBaskets and the services offered using the WealthDesk Platform. WealthDesk does not recommend any WealthBaskets or services offered using the WealthDesk Platform, and is will not be liable for any loss of whatsoever nature arising therefrom. The content and data available on WealthDesk Platform, including but not limited to index value, return numbers and rationale are for information and illustration purposes only. Data used for calculation of returns and other information is provided on the WealthDesk Platform is neither audited nor validated by WealthDesk. Unless otherwise stated, the percentage returns displayed on the WealthDesk Platform for comparing the performance of WealthBaskets with that of any benchmark asset are Compound Annual Growth Rate (CAGR) and risk levels and composition shown in the weightages sections on the WealthDesk Platform are only for reference.
- While care has been taken in preparing the contents provided on the WealthDesk Platform, such contents are provided to you on an “as is” and “as available” basis, without warranty of any kind either express or implied. In particular, no warranty regarding accuracy, suitability or relevance for a particular purpose is given in relation to such contents. WealthDesk, its Directors, and its employees make no representations, endorsements or warranties of any kind about the services, content, information and/or data contained on the WealthDesk Platform.
- WealthBaskets denote a unique combination of securities created by an Investment Advisor or Research Analyst duly registered with the SEBI. As such, WealthBaskets themselves are not a tradeable instrument and do not have any inherent value other than the aggregate value of the constituent securities.
- The performance of WealthBaskets may or may not be sustained in future, and the same is not to be used as a basis for comparison with other investments. The names of the WealthBaskets do not indicate its future prospects and returns in any manner.
- All WealthBaskets are offered to you on the basis of the investment advice offered to you by an Investment Advisor or Research Analyst duly registered with the SEBI Investment, in compliance with applicable laws and SEBI regulations. You are advised to read the terms of the investment adviser agreement before availing any investment advice over the WealthDesk Platform or a third-party site or read the terms of service of such Research Analyst before acting on its recommendation/ research report.
- Before making a recommendation to invest in a particular WealthBasket, the Investment Advisor is required to assess your risk profile to ascertain the suitability of the concerned WealthBasket. Such an assessment is not binding on you and you may choose not to invest based on such assessment. By deciding to invest, you accept that you have evaluated the concerned WealthBasket independent of the advice provided by the Investment Advisor. As such, no liability in respect
of such investment decision shall attach to the Investment Advisor. Your decision, action or omission to transact in WealthBaskets shall be based on your own independent evaluation of the risks and rewards of the investments and your own verification of all the relevant facts, including financial and other circumstances and a proper evaluation thereof. WealthDesk and its corporate affiliates (including third parties affiliated with WealthDesk) shall not be liable and responsible in case you fail to transact or in case of your failure to omit transaction in WealthBaskets or acting/ omitting to act on the rebalancing changes notified by such Investment Adviser or Research Analyst. Rebalancing means the process of realigning the weightings of a portfolio of assets or Securities in WealthBaskets by the Investment Adviser or Research Analyst.
- WealthBaskets are not to be construed as a product based on or linked to an index developed by the NSE Indices as WealthDesk is not in the index manufacturing business and WealthBaskets is not an independent index. WealthBaskets are not licensed to be traded on any exchange, trading or settling venue outside India.
REGARDING INVESTING IN EQUITIES
- Information present on WealthDesk Platform shall not be considered as a recommendation or solicitation of an investment or investment strategy. You as an investor are responsible for your investment decisions and are responsible to validate all the information used to make the investment decision. You understand you’re your investment decision is based on your personal investment needs and risk tolerance; the performance information available on the WealthDesk Platform is
one amongst many other things that you should consider while making an investment decision. Past performance does not guarantee future returns and the performance of WealthBaskets are subject to market risk. Investments in the securities market are subject to market risks and you should read all the related documents carefully before investing.
- Investing in securities including equities and derivatives involves certain risks and considerations associated generally with making investments in securities. The value of the portfolio investments may be affected generally by factors affecting financial markets, such as price and volume, volatility in interest rates, currency exchange rates, changes in regulatory and administrative policies of the Government or any other appropriate authority (including tax laws) or
other political and economic developments. Consequently, there can be no assurance that the objective of a WealthBasket would be achieved.
- The value of a WealthBasket may fluctuate and can go up or down. You are advised to carefully review the terms of investing, including the agreement with the Investment Adviser, and other related documents carefully and in their entirety and consult your legal, tax and financial advisors to determine possible legal, tax and financial or any other consequences of investing under a WealthBasket, before making an investment decision.
- The composition of a WealthBasket is subject to changes. The benchmark of the WealthBaskets may change from time to time in the future. Trading volumes, settlement periods and transfer procedures may restrict the liquidity of investments in WealthBaskets.
- Individual returns of investors for a particular WealthBasket may vary significantly; so also, the performance of a particular WealthBasket may vary from the depicted data on performance of the concerned WealthBasket due to factors such as timing of entry and exit, timing of additional flows and redemptions, individual client mandates, specific portfolio construction characteristics or structural parameters, which may have a bearing on individual portfolio performance. No claims may be made or will be entertained for any variances between the performance depictions and individual portfolio performance.
- Financial products and instruments are subject to market risks and yields may fluctuate depending on various factors affecting capital/debt markets. There is no assurance or guarantee that the objectives of the WealthBasket will be achieved. Please note that past performance of the financial products, instruments and WealthBaskets does not necessarily indicate the future prospects and performance thereof. Such past performance may or may not be sustained in future.
- An investment adviser’s investment advice may not be always profitable, as actual market movements may be at variance with anticipated trends. You are not being offered any guaranteed or assured returns.
REGARDING LEGAL MATTERS
- Due to the global nature of the Internet, the WealthDesk Platform may be accessed by users in countries other than India. WealthDesk makes no warranties that materials on the WealthDesk Platform are appropriate or available for use in such jurisdictions. If it is illegal or prohibited for you to access or use the WealthDesk Platform, then you should refrain from doing so. If you choose to access the WealthDesk Platform from outside India, then you do so on their own initiative and are responsible for compliance with all applicable laws and regulations.
- WealthDesk hereby expressly disclaims any implied warranties imputed by the laws of any jurisdiction. WealthDesk considers itself and intends to be subject to the jurisdiction only of the courts of Mumbai, India. If you don’t agree with any of our disclaimers above, then do not transact in WealthBaskets.
- This site is specifically for users in the territory of India. Although the access to users outside India is not denied, WealthDesk shall have no legal liabilities whatsoever in any laws of any jurisdiction other than India.
Last updated: 03/05/2021
AN IMPORTANT NOTICE FOR INDIVIDUALS WITHIN THE EUROPEAN UNION
The General Data Protection Regulation (GDPR) is a regulation in European Union law on data protection and privacy for all individuals within the European Union (EU) and the European Economic Area (EEA). The GDPR applies to an organisation if it collects data from EU residents or processes such data. We are not involved in either collecting data from EU residents or in processing such data. We do not offer our products or services within the EU and the EEA. As such, we are not required to conform to the stipulations of the GDPR. Therefore, while we endeavour to implement world-class privacy norms, we do not actively seek compliance with the GDPR. If you are an EU citizen, please be advised that by using this Website or transacting with us, you waive all and any entitlement that may otherwise be available to you under the GDPR. We disclaim any liability to ascertain the applicability of GDPR to you and/or to seek your consent of such waiver separately.
AN IMPORTANT NOTICE FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act (CCPA) is a regulation that is intended to enhance privacy rights and consumer protection for residents of California, United States. The CCPA provides certain rights to California residents with respect to their personal data. The CCPA applies to a business that collects consumers’ personal data, which does business in California, and satisfies certain financial thresholds. We are not involved in either collecting data from California residents or in doing business in California. We do not offer our products or services within California. As such, we are not required to conform to the stipulations of the CCPA. Therefore, while we endeavour to implement world-class privacy norms, we do not actively seek compliance with the CCPA. If you are a California resident, please be advised that by using this Website or transacting with us, you waive all and any entitlement that may otherwise be available to you under the CCPA. We disclaim any liability to ascertain the applicability of CCPA to you and/or to seek your consent of such waiver separately
- TERMS USED IN THIS POLICY
- ABOUT THIS POLICY
- OUR COMMITMENT TOWARDS PROTECTING PERSONAL INFORMATION
- WHAT DATA DO WE COLLECT OR PROCESS ABOUT YOU, AND FOR WHAT PURPOSE?
- WHOM DO WE SHARE YOUR DATA WITH?
- WHERE DO WE PROCESS YOUR DATA?
- HOW LONG DO WE RETAIN YOUR DATA?
- WHAT ARE YOUR RIGHTS REGARDING YOUR DATA WITH US?
- SECURITY OF YOUR DATA
- LINK TO OTHER WEBSITES
- COMMUNICATIONS, ETC.
- SECURITY OF DATA
- LIMITATION OF LIABILITY
- DERIVATIVE DATA
- CONTACT DETAILS
TERMS USED IN THIS POLICY
In this Policy:
- “Cookies” mean small files that are placed on your computer, mobile device or any other device by a website, containing, among other information, the details of your browsing history on that website.
- “Personal Data” means any information relating to an identified or identifiable natural person.
- “Service” means a service that we provide for a fee or gratis. You are using our Service when you sign up or sign in to get access to any Service provided by us.
- “we”, “us”, “our”, and “WealthDesk” refer to Wealth Technology & Services Private Limited.
- “WealthBasket” is a selection of Securities in a particular combination that is created and managed by SEBI-registered investment advisors and/or SEBI-registered research analysts which allow you to place purchase orders
for such offering through your stock brokers who are registered with the WealthDesk Platform.
- “WealthDesk Platform” means the set of proprietary APIs, SDKs, tools, plugins, code, technology, content, and services that are made available over the www.wealthdesk.in and includes
the microsites created therefrom (including microsites created on third-party websites).
- “Website” refers to www.wealthdesk.in. You are using our website when you are visiting our website.
- “you” refers to you, as a visitor to the Website, as a user or subscriber of the Services.
ABOUT THIS POLICY
We understand the importance of data and its privacy. This Policy explains the type of information we collect, how we handle your information and comply with the requirements of applicable privacy laws. All your transactions in WealthBaskets – whether
We recommended that you review the privacy statements and policies of any such third parties with whom they interact. We do not make any representations concerning the privacy practices or policies of such third parties
in this Policy by reference.
OUR COMMITMENT TOWARDS PROTECTING PERSONAL INFORMATION
Your privacy is important to us. We will use your personal information only in the manner set out in this Policy. We are committed to safeguarding the privacy of our website visitors, clients, prospects, and other third-parties. This Policy sets out how
we deal with your personal information.
Our commitment towards protecting your personal information includes the following obligations:
- We promise to protect your privacy and treat the information you give us as confidential.
- The information you provide to us will be used by us only for the purpose for which it was sought.
- We will never sell your personal data to anyone.
- Your decision to provide or not to provide any information will respected without question.
WHAT DATA DO WE COLLECT OR PROCESS ABOUT YOU, AND FOR WHAT PURPOSE?
We collect information, including personal data, about you to be able to make the WealthDesk Platform and Services useful to you. This information may be collected by us from the data which you give to us while using our Services or transacting in WealthBaskets
using the WealthDesk Platform or any third-party sites. We may also derive your information from other sources. Such information may, inter alia, include the following:
- Your personal identifiable information including your demographic details (such as your name, gender, marital status, age), contact details (such as your email address, postal addresses, telephone number);
- Your financial information including banking details (such as your bank account no., bank, branch, IFSC), your fiscal details (such as your income, expenses, risk profile), and your monetary goals;
- Your technical Information collected by our technology (such as your browser type, operating system, Internet Protocol (IP) address);
- Information voluntarily provided by you while using our Services (such as engaging with third-parties over the WealthDesk Platform, transacting in WealthBaskets);
- Information generated while you transact on WealthDesk Platform (such as purchase of WealthBaskets);
- Security-related information used by you while accessing the WealthDesk Platform (such as usernames, passwords, email addresses)
- Information which you store on our servers (such as images, documents);
- Information available in the public domain, including over social media platforms (such as your picture, friend list);
- Information pertaining to any other person in respect of whom you make
disclosures through the WealthDesk Platform or while using our Services (such as a nominee). In such case, you must confirm and represent that each of the other investor(s) for whom an enquiry/ transaction has been
made, has agreed to have the information shared by you, disclosed to us and further be shared by us with our business partners.
We may process the data that we have about you, in the following manner.
- We may process data about your use of our website and services (“usage
data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of your visit, page views and website
navigation paths, as well as information about the timing, frequency and pattern of your Service use. The source of the usage data is our analytics tracking system. In addition, we may use third-party analytics tracking
services such as Google Analytics and Facebook Pixel. This usage data may be processed for the purposes of analysing the use of the Website and Services in order to improve our performance metrices, and for communicating
with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely monitoring and improving our Website and Services.
- We may process your data that is provided to us during the course of you taking assessments on our Website (“response data”). The response data may include your name, age, financial goals, and your responses to the questions that we may ask you. The source of the response data is you. The response data may be processed for the purposes of providing our services, ensuring the integrity of our operations and processes, maintaining back-ups of our databases, and for communicating with you. The legal basis for this processing is your consent.
- We may process your information included in your personal profile on our website
(“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details, bank account details, broking account details, and demat account details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services, for providing Services to you, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration and operation of our Website and Services.
- We may process your personal data that are provided in the course of the use of our Services
(“service data”). The service data may include your name, address, telephone number, email address, bank account details, broking account details, and demat account details. The source
of the service data is you. The service data may be processed for the purposes of providing our Services, ensuring the security of our Website and Services, maintaining back-ups of our databases, and for communicating with
you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the
legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- We may process information that you post for publication on our Website or through our
Services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our Website and Services. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- We may process information contained in any enquiry you submit to us regarding our
(“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you and for and for communicating with you. The legal basis for this processing is your consent.
- We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications, promoting our products and services to customers, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract.
- We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our Website (“transaction data”). The transaction data may include your contact details, your banking details, your credit card details, bank account details, broking account details, demat account details, and the details of the transactions carried out by you. The transaction data may be processed for the purpose of supplying the purchased goods and services, keeping proper records of those transactions, and for communicating with you.
The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters, and for communicating with you. The legal basis for this processing is your consent.
- We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business and communications with our business counterparts.
In addition to the specific purposes for which we may process your personal data set out in this Section, we may process any of your personal data identified in this Policy where necessary for:
- the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
- compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We may use your data for the following purposes.
- To create and authenticate your account with the WealthDesk Platform;
- To identify you as a registered user of the WealthDesk Platform and to administer your account;
- To enable you to use the WealthDesk Platform and our Services;
- To enable communications between stock brokers, investment advisors, research analysts and investors and accordingly facilitates purchase and sale transactions of WealthBaskets by you;
- To facilitate the operations of the WealthDesk Platform, including the offer of investment advice to you by investment advisors and research analysts; the creation and management of WealthBaskets, the launch, management and tracking of portfolios across all WealthBaskets, the interaction and communication between you, stock brokers, investment advisors, and research analysts, the organisation of information relating to the aforementioned activities;
- To publish fact-based views and opinions regarding, inter alia, the WealthBaskets and the Services offered on the WealthDesk Platform, based on the information available on the WealthDesk Platform;
- To improve the quality of your experience when you interact with the WealthDesk Platform and use our Services;
- To send you notifications, verification message(s) or email(s);
- To allow our customer service to contact you, if necessary or respond to your queries and assist you with customer service or technical support;
- To send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes, customer analysis, market research and statistics;
- To request for reviews of our Services or any other improvements;
- To prevent and detect fraud or abuse of our Services as well as to prevent, detect and investigate any potential unlawful or prohibited activities.
WHOM DO WE SHARE YOUR DATA WITH?
Your personal data shall never be shared without your consent. You hereby permit us an expressly consent to the use of your personal data for the purposes listed below.
We may share your data with legal or statutory or regulatory agencies or authorities; our employees, officers, advisors and agents; our partners, transactional counterparties such as including stock brokers, investment advisors, research analysts, suppliers or service providers acting on our behalf (as the case may be), etc. solely for the purposes listed in this Policy.
We may share the information given by you with third parties where we feel that such third parties may improve the quality of services imparted by us to you.
We may share your personal data with our service providers, ad-servicers, ad-platforms and third parties for research, marketing, analytics and other purposes, provided such information does not identify you particularly. We may share legally permitted information with third party that we may engage to perform certain tasks including but not limited to payment processing, data hosting, and data processing platforms to understand how you engage with us and develop an understanding
of how you prefer to interact with us. We may hire such third party for market research, surveys, etc. and may provide them with legally permittable information specifically for use in connection therewith. All such information
will be shared in a manner which does not identify you particularly.
We may collect financial information and disclose the same to third-parties as necessary to complete billing operations. We may require you to make payments for the Services availed by using your credit card, wire transfer, debit card or cheque/cash. Verification of credit information, however, is accomplished solely by you through the authentication process. Your credit card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. We provide you an option not to save your payment details. You are advised, however, that internet technology is not fully safe and you should exercise discretion while using the same.
In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in
an administrative or out-of-court procedure.
We only share your personal data on a partial and “need-to-know” basis with any third party. We shall take all reasonable steps to ensure that the confidentiality of your information is maintained by imposing strict confidentiality standards on all the third parties with whom we part this information. In all circumstances we shall ensure that your personal information is protected by strict confidentiality agreement. We shall not allow any third parties to retain your personal information longer than what is warranted by the nature of services rendered.
By agreeing to avail the service offered by WealthDesk, you agreed to the collection, use and sharing of your personal data or Information by WealthDesk as per the terms of this Policy. You always have the right to refuse or withdraw your consent to share/dissemination of your personal data by contacting us as per the details provided in this Policy. However, in such an event, you may no longer be eligible to avail our services.
We will not sell, share, rent or otherwise intentionally transfer your name, address, telephone number or e-mail address to market research companies, direct marketing companies or anyone else. The only exceptions when we may disclose your personal information to third parties are as follows:
- You request us to share, or consent to us sharing, your data with the third parties for a specified purpose
- We provide your responses to a third party who is contractually bound to keep the information confidential and use it only for research or statistical purposes In the rare but possible circumstance that the information is subject to disclosure pursuant to judicial or other government subpoenas, warrants, orders or for similar legal or regulatory requirements.
WHERE DO WE PROCESS AND STORE YOUR DATA?
Your data will be processed and stored in India.
HOW LONG DO WE RETAIN YOUR DATA?
Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Subject to exceptions based on your continuing use of the WealthDesk Platform, we intend retain your personal
data as follows:
- Usage data will be retained for a minimum period of one week following the date of your visit, and for a maximum period of ten years following the date of your last visit.
- Response data will be retained for a minimum period of one month following the submission of your response, and for a maximum period of ten years following the submission of your last response.
- Profile data will be retained for a minimum period of one day following the date of deletion of your profile on our Website, and for a maximum period of ten years following such deletion.
- Service data will be retained for a minimum period of one month following the fulfilment of the Service, and for a maximum period of ten years following the last date on which any obligation in respect of such Service concludes.
- Publication data will be retained for a minimum period of one week following the publication of such data, and for a maximum period of ten years following the date on which such data is removed from such publication.
- Enquiry data will be retained for a minimum period of one day following the date of the enquiry, and for a maximum period of ten years following the date of the enquiry.
- Customer relationship data will be retained for a minimum period of one month following the conclusion of the said relationship, and for a maximum period of ten years following the conclusion of the said relationship.
- Transaction data will be retained for a minimum period of one week following the date of the transaction, and for a maximum period of ten years following the date of the last transaction.
- Notification data will be retained for a minimum period of one day following the date of unsubscribing from our newsletters, and for a maximum period of ten years following the date of request for such unsubscribing.
- Correspondence data will be retained for a minimum period of one day following the date of the communication, and for a maximum period of twenty years following the date of the communication.
In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
|Sr. No.||Category of Data||Factors on which period of retention will be based|
|1.||Usage data||Parameters of usage being analysed|
|2.||Response data||Requirements of law|
|3.||Profile data||Nature of utilization of profile|
|4.||Service data||Nature of Service; requirements of law|
|5.||Publication data||Means of publication; citation of publication in other works|
|6.||Enquiry data||Means of enquiry; nature of Service enquired for|
|7.||Customer relationship data||Nature of relationship; requirements of law|
|8.||Transaction data||Nature of transaction; requirements of law|
|9.||Notification data||Terms of opt-in|
|10.||Correspondence data||Nature of correspondence; requirements of law|
Notwithstanding the foregoing provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or where we reasonably believe that the retention of such data is required in order to protect your or any third-party interest.
WHAT ARE YOUR RIGHTS REGARDING YOUR DATA WITH US?
This Section summarises the rights that you have in respect of your data. Please note that some of the rights available to you are subject to the requirements of the applicable law. You may peruse the relevant laws for a complete understanding your rights.
Your principal rights concerning your personal data are as below:
- Right to access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes
of the processing, the categories of personal data concerned and the recipients of the personal data. Subject to the condition that the rights and freedoms of others are not affected, we will supply to you a copy of your
personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
- Right to rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
- Right to erasure: In certain circumstances you have the right to the erasure of your personal data without undue delay. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims
- Right to restrict processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you do not desire erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of
that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence
of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
- Right to object to processing: In some circumstances, you have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing
is for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- Right to data portability: To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However,
this right does not apply where it would adversely affect the legal or contractual rights of third-parties or where the law requires otherwise.
You may exercise any of your rights in relation to your personal data by a written notice to us. In order for us to comply with your request, your notice must clearly state the right that you wish to exercise and identify your information in respect of which you wish to exercise such right. Please note that as a security measure, we may require you to verify your identity before accepting any request concerning your personal data.
A cookie is a file containing a unique identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain any information that personally identifies you, but personal information that we store about you may be linked to the information stored in and obtained from cookies. You may change
the options on your web browser and block cookies. However, blocking cookies may disable certain features on the WealthDesk Platform, and may hinder an otherwise seamless experience to use our Services.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, that is, when the web browser is closed. We use both Session and Persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide you with services available through the website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without
these Cookies, the services that you have asked for cannot be provided, and We only use these Cookies to provide you with those services.
- Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
- Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices you make when you use the website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the website.
- We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behavior on our website and on other websites across the web using cookies. You can view, delete or add interest categories associated with your browser by visiting:
https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these
- Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Opera: http://www.opera.com/help/tutorials/security/cookies/
- Internet Explorer:
- Safari: https://support.apple.com/kb/PH21411
- Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
SECURITY OF YOUR DATA
We will make commercially reasonably efforts to secure the data provided to us and adopt reasonable security practices to ensure that the information collected is secured as per the standards required by applicable laws in India. Our information security policy may contain managerial, technical, operational and physical security control measures that may be commensurate with the information being protected herein. We are committed to continuously develop and implement administrative,
technical and physical security measures to protect such information from unauthorized access or against loss, misuse or alteration. While we endeavour to take all reasonable and appropriate steps to keep secure the information
collected and prevent unauthorized access, you acknowledge that the internet is not entirely secure and that we cannot and therefore do not provide any absolute assurance regarding the security of the information collected.
LINK TO OTHER WEBSITES
You may receive email updates from us through our newsletters, surveys, offers, and other promotional materials related to our Services. We hope you will find these updates interesting and informative. If you wish not to receive them, please click on the “unsubscribe” link or follow the instructions in each message.
You may share your feedback and comments with us, including that relating to an issue or incidence. To report an incidence regarding your data, you may contact us using our contact details and inform us about such incidence.
LIMITATION OF LIABILITY
We are not be responsible for verifying the authenticity of the information supplied by you. In case of any erroneous data, our liability is limited to removal of such data from our system. We are not liable for any data loss or theft due to an unauthorized access to your computer or device. We shall not be responsible for any breach of security or for any actions of any third parties that receives your personal data or events that are beyond our reasonable control including,
We may generate derived data and anonymous statistical information based on the data available on the WealthDesk Platform. Such derived data and anonymous statistical information shall not identify you at a personal level, and shall be exclusively our property. We may use such data or information for any legitimate purpose as we may determine, without any compensation to you.
This Website is owned and operated by Wealth Technology & Services Private Limited.
- We are registered in India under registration number U74999MH2016PTC281896, and our registered office address is: 3rd Floor, A 305, Rustomjee Central Park, Andheri-Kurla Road, Opp. Kanakia Wall Street, Andheri (East), Mumbai – 400059, Maharashtra, India
- You can contact us (a) by post: at our registered office address provided above; (b) by email: on firstname.lastname@example.org; (c) by telephone: on the contact number published on www.wealthdesk.in; (d) by Website: by using our website contact form on https://wealthdesk.in/contact-us.
- For any request that is not attended to your satisfaction, you may reach out to Mr. Abhishek Upadhyay,Grievance Officer, on email@example.com or on 7506454580
We appreciate you taking the time to read this policy. We know that you are placing your trust in us when you choose to share your personal information with us and we intend to use it responsibly.