Privacy Policy

Effective as of 01 January 2022

Legal Notice: This website is an information only website of Elever Investment Adviser Private Limited, a private limited company incorporated under the Companies Act, 2013 having its office at 301/302, Third Floor Saket, Callipolis, Surajpur Main Road, Doddakannelli, Bengaluru – 560035, that features the offerings for various Elever products/services and allow users to register and subscribe to robo-advisory services offered by Elever Investment Adviser Private Limited (“Elever,” “we,” “us” or “our“).

We, have established this privacy policy to explain how we collect, use, share and protect information that we may gather from www.elever.app. and the Elever App, an artificial intelligence (AI) capable robo-advisory platform (collectively, “Sites“). This policy does not apply to information that we may collect from you outside of our Sites, such as third party service providers, over the phone, by fax, or through conventional mail. In addition, please note that all users and records are protected by Elever as required by applicable law in the Republic of India.

Scope of this Policy

Elever respects the privacy of our users (“user” or “you”). This privacy policy (the “Policy” or the "Privacy Policy”) describes how Elever collects, uses, disclose, otherwise processes and safeguard your information when you visit our Sites. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the Sites.

We are committed to protecting the privacy of our users and customers. This Privacy Policy is especially directed at:

  • visitors and subscribers of Elever Sites;
  • natural persons contacting us through the contact or other forms available on the website;
  • users signing in to use our services.

This Privacy Policy is intended to inform you how we gather, define, and use information that could identify you, such as your name, email address, address, other contact details, online identifiers or other information that you provide to us when using our Sites or when relying on our services.

This policy includes a description of your data protection rights as laid down under the law for the time being inforce.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Sites, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Sites after the date such revised Privacy Policy is posted.

User Consent

By submitting Personal Information through our Sites, you agree to the terms of this Privacy Policy and you expressly give your voluntary consent to the collection, use and disclosure of the Personal Information in accordance with this Privacy Policy.

Personal Information You Provide

You can access Elever website and information provided therein without divulging any personal information. Our Sites do not collect personal information about individuals except when such individuals specifically provide such information on a voluntary basis (for example, registering to avail our services, using and downloading Elever App; for conducting KYC check and as part of the Risk Questionnaire, accessing your 'Elever Money Score', consent based financial tracking, or providing Execution Consent for your Brokerage Account, requesting additional information by contacting us; signing up for newsletter; requesting help; or accessing, adding to, or changing the information on your account information/ registration/ signup window of the Elever App). When you register or sign up or Login to avail our services on our App, we may collect information regarding you. This personal information may be collected on our Sites, or via electronic mail or via telephone.

If you are using the Elever website as a first time visitor - The information we may collect includes certain data about your interaction with our website, such as pages visited and average time spent on the website, your internet protocol address, the unique identifier of your device and device information such as operating system, operating system version, browser plugins, crashes, system activity, hardware settings, date and time of your request and referral URL, and cookies that may uniquely identify your browser and mobile application. We use this data to analyze how you use our website and improve the information provided through the website. We may also supplement the information we collect with information we receive from third parties. For example, we may use marketing segments developed by us or other companies to customize certain services to your local area and provide relevant offers tailored to you.

In order to avail the services offered by or on the Elever App, users are required to register for an account on our Elever App and have to provide information and data (“Personal Information”) classified as ‘Sensitive Personal Information’ under Regulation 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”). Personal Information provided in acceptance of this Policy shall amount to written consent under Regulation 5 of the SPDI Rules.

As such the Elever App will have access to your name, Mobile number, Date of birth, PAN Number and email address only. This initial registration would involve providing a valid email, Mobile number, Date of birth, Permanent Account Number (“PAN”) and Name to generate the User name and password (collectively, “Login Credentials”) after due OTP verification. You may be asked to give us additional information in order to use certain features of the Elever App.

Further, we collect personal information when you are using our Financial Planning tools or registering with us for setting up of an Investment Account. This may include, inter alia, conducting KYC check and as part of the Risk Questionnaire, accessing the ‘Elever Money Score’, conducting KRA check, consent based financial tracking, or providing Execution Consent for your Brokerage Account. This information is primarily collected for regulatory compliance with applicable laws in order to enable/ create and/or activate your account with Brokerage Houses, to enable you to conduct online transactions. This information including KYC, Risk Questionnaire and financial information collected to generate the ‘Elever Money Score’ and to conduct consent based financial tracking shall be stored with us and shared with select third parties such as our group companies, KYC Registration Agencies (KRA), KYC solution providers, RBI approved Account Aggregators, Geo-Location based Intelligence providers, Brokerage Houses, Payment Gateway providers in order to enable us to complete your registration as a client with us and to process any transaction requests that you authorize, maintain a record of your transactions and holdings, generate and send reminders, alerts, notifications to you for transactions, recommended goals, upcoming funds transfers etc.

We may collect personal information about your transactions, and how you interact with third parties such as your brokerage house when you conduct trading transactions such as the purchase and/or redemption of securities, units in a mutual fund scheme. This information helps us to provide our services to you. We encourage you to read the Terms and Conditions to understand further about how your information is collected and used.

The personally identifiable information, such as your name, address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you choose to participate in various activities related to the Sites. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Sites.

Use of Your Information

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you to:

  • Identify you as a user in our system;
  • Respond to your queries about the services;
  • Deliver to you any notices, alerts, or communications relevant to your use of other Services;
  • Offer you other products or services that we believe may be of interest to you;
  • Aggregate the anonymised information from registered users to perform market research, project planning, product development, troubleshoot problems, analyse user behaviour, marketing purposes, and promotions; and Enforce this Agreement and any terms thereof;
  • Use the information we collected online or offline in conjunction with the personal information you have provided us with, or information that is publicly available from other sources to customize your experience and our communication with you both online and offline;
  • Offer you other products or services that we believe may be of interest to you;
  • Prevent and detect fraud or abuse of our services as well as to prevent, detect and investigate any potential unlawful or prohibited activities.

We generally do not disclose your personal information to other companies that provide services for us, where/ when such information is shared to it is disclosed on a need-to-know basis and based on specific consent. We may use third party service providers to enable us in providing some services to you such as opening and operating Brokerage account, conducting KRA check, conducting KYC check and onboarding, sending e-mail messages, SMS, WhatsApp and in-app notifications, analysis of non personally identifiable information for product/ service personalization, to you, customer support (online & offline) collecting a fee for our services, and providing product & technical support regarding an issue with any feature or functionality on the Sites.

When you provide us with your personal information either while setting up an account with us or later, it is kept maintained by the division that is responsible for your account management. You can view and/or update/edit this information by logging on to your account through our Elever app.

Personal information collected will not be used for any purposes other than as mentioned herein. You may withdraw your consent for the use of the personal information at any time by deactivating your account. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. In the event you choose to withdraw your consent for collecting and processing your personal data, we will be unable to provide you with our products and services.

Disclosure of Your Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

i. By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

ii. Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email/SMS/WhatsApp delivery, hosting services, customer service, and marketing assistance. Such third parties are required to maintain the confidentiality of the information we provide to them under contract and under law.

iii. Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

iv. Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. 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.

v. Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

vi. Employees

All employees of Elever have been selected in accordance with our strict security policies and practices and are bound by confidentiality obligations. Elever employees are subject to stern disciplinary action, including termination, civil liability, and criminal prosecution, if they fail to meet any of these obligations, as stated.

vii. No sale, distribution, trade, lease or rent of Personal information of users

Under no circumstances, Elever will sell, distribute, trade, lease or rent the Personal Information of its Users to anyone, for any reason(s).

Use of Cookies

The Sites use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you. We use cookies to keep track of how you are using the Sites to tailor Web and App content to your interests. Elever cookies do not contain personal information about the Registered Users subscribed to our services.

We will not share or sell non-aggregated information contained within cookies to any third party.

You also have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If, however, you choose to decline cookies, you may not be able to fully experience the interactive features of our Sites or have some of our services on the Sites function properly, or at all.

Our Commitment to Data Security

Elever follows industry best practices, using open and known principles when transferring and storing your data. We believe the biggest threat to the security and privacy of your data is if someone – probably someone you know – gains access to any of your devices. Remember to keep your password safe and secret to prevent unauthorized access to your account. If you think that the security of your account has been compromised, change your password and contact us at support@elever.app immediately for further assistance.

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect.

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information. For the avoidance of doubt, if any personal information is compromised despite our efforts to prevent the occurrence of the same, you shall not hold us liable for such breach of privacy protection under this privacy policy.

It may be noted that we may retain the data as may be provided to us till such time as may be provided under the law and as required to efficiently provide service to our users.

Exercise Your Rights

We respect your right to be informed, access, correct, request deletion or request restriction, portability, objection, and rights in relation to automated decision making and profiling, in our usage of your personal information as required by applicable law. We also take steps to ensure that the personal information we collect is accurate and up to date and deleted when data is no longer required. Your rights are subject to defined conditions and feasibility to exercise such rights and subject to geo locations applicability.

Your Rights:

  • You have the right to know what personal information we maintain about you subject to availability.
  • We will provide you with a copy of your personal information in a structured, commonly used and machine-readable format on request subject to availability.
  • If your personal information is incorrect or incomplete, you have the right to review and ask us to update it.
  • You have the right to object to our processing of your personal information only if the data is processed.
  • You can also ask us to delete or restrict how we use your personal information, but this right is determined by applicable law and may impact your access to some of our services.
  • You have the right to access your personal information which may vary from visitor to visitor.
  • You have a right to object to processing of your personal information where it is so conducted by automated means and involves any kind of decision-making subject to discovery that your data was used for automated means.

Our Legal Obligation to You

We are bound by the (Indian) Information Technology Act, 2000, and comply with all its provisions. Under Section 43A of the (Indian) Information Technology Act, 2000, Elever and all its Service Providers are obliged to maintain reasonable security procedures to safeguard your data. Under Regulation 5 of the Information Technology (Reasonable Security and Procedures and Sensitive Personal Data or Information) Rules, 2011, we are obliged to provide every registered user of Elever with a readable copy of the personal information you have provided us.

Contact Us

If you have questions or comments or complaints about this Privacy Policy or any action is required in relation to your personal information, please contact us at support@elever.app.

Changes to the Privacy Policy

We will occasionally amend this Privacy Policy to company with regulatory obligations and legal developments and reflect company and customer feedback. We reserve the right to change, modify, add, or remove portions of this policy at any time. If we materially change our use of your personal information, we will announce such a change on our website, and will also note it in this Privacy Policy. The effective date of this Privacy Policy is documented at the beginning of the Privacy Policy. If you have any questions about our privacy policy, please contact us in writing at support@elever.app.