Welcome to www.clovekwealth.com (“Website”/”we”/”us”/”our”/”our platform”). This Website is owned and operated by Clovek Wealth Management Pvt. Ltd., whose registered office is at B 915, Advant IT Park, Sector – 142,Noida, Gautam Buddha Nagar -201305 IN.
1. ABSOLUTE CONFIDENTIALITY
1.1. At Clovek Wealth Management Pvt. Ltd. (also referred to as “Website” or “We” or “Our”), we are committed to protecting your privacy and ensuring the security of any information including personal information (“Information”) received from the customer/visitor/user (“You”/”Your”/“Customer”/”User”). For Us, the confidentiality of Our Customers is a top priority. We strictly adhere to the requirements of the data protection laws established in India and this Privacy Policy (“Policy”) is published in accordance with including but not limited to Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011; other relevant Statutes, etc.
1.2. We will use the Information sensibly and carefully, and only in accordance with this Policy as well as Law of the land. We maintain compliance with the highest standards of website privacy, so our Users can securely avail Our services.
1.3. Please read this Policy carefully. If you do not agree with the terms of this Policy, please do not access the Website.
1.4. We may revise this Policy from time to time by updating this page, and so we urge You to review it periodically to ensure that You agree with any such changes that We make. We will make best efforts to inform You of any important amendments by e-mail, message on the Website or notification in Your Account. However, it is your responsibility to check this Policy regularly to ensure that You agree with it and Your continued use of the Website will be deemed to be Your acceptance of any changes that We make. Last updated on: 08.04.2020.
2. WHAT INFORMATION WE COLLECT ABOUT YOU AND WHY
2.1. We may collect certain Information from You while you access our Website in a variety of ways. However, wherever required as per Law, We shall be obtaining necessary consents from You for the purpose of usage of Information before collecting such Information. Some of the Information that we will collect when you access our Website is described below.
2.2. When a User creates a new account:
When You create a new account to use our services, we request the following information for KYC purposes: Name, Father’s Name, Date of Birth, PAN Number, Aadhaar Number, Gender, Marital Status, Residential Status, Employment Sector, Nationality, Residential Address, Email address, User Id, Password.
2.3. When a Customer contacts us or submits a query, we store the details shared by the Customer such as name, email address, phone number and any other relevant information which the Customer shares with us.
2.4. We do not collect any information about User’s online activity once the User signs out from the Website.
2.5. We use third party analytics services in order to better understand User engagement with our services. When a User browses or uses the services, these third-party analytics services may collect the following type of information:
2.5.1. Page Information
– URL – the URL of the page the user is viewing
– Title – the title of the page the user is viewing
2.5.2. Browser Information
– Browser name – the browser the user is using
– Viewport or Viewing pane – the size of the browser window
– Screen resolution – the resolution of the user’s screen
– Java enabled – whether or not the user has Java enabled
– Flash version – what version of Flash the user is using
2.5.3. User Information
– Approximate Location – this is derived from the IP address where the hit originated.
– Language – derived from the language settings of the browser.
They may also use web logs or web beacons and may set and access cookies on their computer or other device. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). — Google Analytics uses cookies to help the website analyse how users use the Site and enhance your experience when you use the Service. For more information on how Google uses this data, go to https://www.google.com/policies/privacy/partners/.
2.6. Apart from what is explained above, the purpose of collecting your information is given below:
– With respect to Analytics data collected from all Users, the purpose is to better understand user engagement with our services and to enhance their experience.
– Specific Personal Information is collected only post your confirmation for Know Your Customer (KYC) purposes and to help provide relevant services like creation of financial plan/investment advice/estate planning etc.
– For onboarding clients, We are collecting Information for creation of financial plan/investment advice/estate planning.
2.7. We shall, prior to the collection of the Information provide an option to the provider of the Information to not to provide the Information sought to be collected. The provider of the Information shall, at any time while availing Our services or otherwise, have an option to withdraw its consent given earlier to Us. Such withdrawal of the consent should be sent in writing to Us. In the case You do not provide or later on withdraw Your consent, We have the option not to provide the services for which such Information was sought.
3. HOW WE USE THE INFORMATION COLLECTED FROM YOU
3.1. For user information:
For all visitors, We will use Local Storage Objects (LSOs) to store content information, preferences and to keep them signed -in. We identify User’s signed-in state with a token and a user id. The LSO token will expire when user logs out of our Website. The LSO token automatically expires after 300 seconds on our Website.
We process this information for KYC purposes and to create and provide financial planning and advice.
3.2. For analytics data:
We do not collect and store any analytics data on our own. We rely on our third party analytics service provider to store the analytics data like google analytics. For more information on how Google uses this data, go to https://www.google.com/policies/privacy/partners/.
This data is used to better understand user engagement with our services and platform and to enhance their experience.
4. WITH WHOM DO WE SHARE YOUR INFORMATION
4.1. Third-Party Service Providers
We will never rent or sell customer information or data to anyone. We may share your Information with third parties that perform services for us or on our behalf including but not limited to data analysis, etc., after receiving explicit consent from You. This will be for the purpose of offering services outlined on our Website. With respect to analytics data, we currently, share only with google. However, we may integrate more analytics and third – party services/instrumentation tools in the future. As per law, Your Information shall be protected at their end as per their respective privacy policies.
4.2. Affiliates
We may disclose Your Information with our affiliates only in a situation where such disclosure is required to complete the task assigned to Us by You and shall be used only for the purpose for which the said Information has been disclosed to them. If such Information is intended to be used for any other purpose, consent shall be taken from You. As per law, Your Information shall also be protected at their end as per their respective privacy policies. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us, other entities/persons whom we closely work with.
4.3. Sale or Bankruptcy
If We reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, We may transfer Your information to the successor entity. If We go out of business or enter bankruptcy, Your Information would be an asset transferred or acquired by a third party.
As with any business, it is possible that, We might sell all or a portion of our assets, undergo a merger, or are acquired by another entity. In such transactions, User/Customer information is typically one of the transferred business assets. Accordingly, in the event that Our assets, are acquired by a third party, such Information may be one of the assets that is transferred or acquired by a third party. Under such circumstances, We would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy. You acknowledge that such transfers may occur, and that any acquirer of “www.clovekwealth.com” may continue to process Your Information as set forth in this Privacy Policy.
5. DISCLOSURE OF INFORMATION
5.1. We will not disclose Your personal information to any third Party without taking prior permission from You. However, we will not take any permission when the Information is required to be shared as per Law, for example we may share Your information with Government agencies mandated under the law to obtain the Information for the purposes of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences.
6. TRANSFER OF INFORMATION
6.1. We may transfer the Information to any other body corporate or a person in India, or located in any other country, that ensures the same level of data protection that is adhered to by the body corporate as provided as per law.
6.2. The transfer may be allowed only if it is necessary for the performance of the lawful contract between the body corporate or any person on its behalf and provider of the Information or where such person has consented to data transfer.
7. HOW WE USE COOKIES
7.1. “Cookies” are small pieces of information placed by a website onto your computer’s hard drive. We use cookies to analyse data about our web page traffic, which helps us save Your preferences for Your future visits. This allows us to customize our Website according to your interests, which will enable us to deliver a more personalized service to our Customers. You may choose to accept or decline cookies. Please be aware that by declining cookies you may be unable to use our Website to its fullest capability.
8. SECURITY POLICY
8.1 We are committed to keeping Your data secure and We take necessary measures to protect Our Customer’s Information. We are hosted on a Virtual Private Cloud on Amazon Web Services which provides a secure and scalable technology platform to ensure we can provide you services securely and reliably. Our infrastructure is launched in compliance with the AWS Well Architected Framework and from a security perspective incorporates practices from the AWS Cloud Adoption Framework.
8.2. We use HTTPS protocol for our platform. All communication between the platform and our servers are protected via 256bit encrypted HTTPS protocol. This prevents MITM (Man in the Middle) attacks on our platform and connection between us and our user is fully secure. We have strict network segmentation and isolation of environments and services in place.
9. UPDATE YOUR INFORMATION
9.1. We may permit You to review the Information You have provided which are found to be inaccurate or deficient and shall be corrected or amended as feasible by:
– Logging into Your account settings and updating Your account.
– Contacting Us using the contact information provided below.
9.2.However, We shall not be responsible for the authenticity of any Information provided by You.
10. DATA RETENTION
10.1. We retain the information provided by You only till such time as it is required to be retained to serve You or to comply with the Law of the land for purposes including but not limited to prevent fraud, assist with any investigations, etc.
10.2. In some circumstances, We may anonymise your personal 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.
10.3 In case of Information collected through third party service providers, We are dependent on their respective policies.
11. CONTACT INFORMATION
11.1 If you have any questions about this Privacy Policy, please contact our Grievance Officer at info@clovekwealth.com and +0120-4953325
11.2 In case you want to reach out to our Customer care, please contact at info@clovekwealth.com and +0120-4953325