PRIVACY POLICY

Last updated on November 1, 2021

This Privacy Policy governs the website www.ebullion.in (“Website") and the applications for devices operating on android and iOS operating systems, namely “eBullion” (collectively, the “Platform”) operated by EBULLION PRIVATE LIMITED ("eBullion”," "we," "us," "our"), the services offered on the Platform in relation to the precious metals offered for sale on the Platform (“Product”), including without limitation, the sale, purchase and management on the Platform, and the features, software, content and information offered by us on the Platform (collectively, “Services”).

We aim at being a mobile application and website based precious metals investment platform and service provider, for persons registered with us on the Platform and/or on the platform offered through our partner and/or affiliates. This privacy policy ("Policy") discloses the practices and policies adopted by eBullion for collecting, storing, retrieving, handling, possessing, processing, disclosing, transferring, or using personal and/or sensitive information (“Information”), which it may receive from the persons who view, access, visit and use the Platform and/or Services (collectively “you”, “your”). The Policy seeks to comply with the provisions of the Information Technology Act, 2000 (“Act”) and the Information Technology (Reasonable security practices, procedures and sensitive personal data or information) Rules, 2011 ("Rules"), as amended and updated from time to time. Please also read our Terms and Conditions of Use available at www.eBullion.in which describes the terms under which you may use our Services.

Please read this Policy carefully to make sure you understand how your Information will be handled by us. If you continue to access and view the Platform or use any of our Services, you will be deemed to have read and accepted this Policy and further, will be deemed to have provided us with your express consent to use and disclose your Information in accordance with this Policy. If you do not agree with this Policy, you should not continue accessing and/or using the Platform and/or the Services.

Our access and use of your Information are determined by the Services that you access and use on any Platform. eBullion uses the Information collected from you or about you for the purposes of inter alia, operating the Platform, providing Services to you, ensuring the security of our Platform and Services, maintaining back-ups of our databases, and communicating with you.

Account Information: When you set up your account with eBullion on any Platform, in order to register on the Platform and/or avail Services, you are required to provide us with certain Information. Such Information may include without limitation, your name, user identifications and passwords, residential or work address, billing and/or shipping address, email addresses, telephone numbers, identity information such as your permanent account number, Aadhaar Identification number, goods and services tax registration number (if applicable), date of birth, gender, your preferences and interest and such other Information. Usage Information: Such Information may include without limitation, your IP Address, application or website data logs, applications installed, log files, diagnostic, crash reports, performance of logs and reports, and such other service-usage Information.

Payment related Information: Payment information may include details regarding your payment reference identification and GST tax reference identification.

Device related Information: Such Information may include specific information relating to the device which you use to access, install or use a Platform. It includes Information such as your IP Address, geographical location, mobile network, telephone number, device identifiers, operating system, referral source, length of visit, page views and Platform navigation paths, security-related information that you use for our Platform, as well as information about the timing, frequency and pattern of use of the Services.

Services related Information: The Information may include without limitation, the details of the Services provided to you on the Platform, such as sale, purchase, redemption and/or delivery of the Products.

Cookies: We access and use Information obtained through cookies, as set out below in detail.

Your Information will be used by eBullion only for the following purposes:

  1. providing safe, efficient, smooth and customised experience on the Platform;
  2. providing the Services;
  3. maintaining a confidential database;
  4. enforcing our Terms and Conditions of Use, and mitigating and protecting you from fraud and other criminal activities;
  5. for internal operations such as troubleshooting, data analysis, research, testing and service improvement of a Platform;
  6. for communicating with you and sending you important notices relating to our Platform, new products or services, payment reminders and other updates, including any update in this Policy or under our Terms and Conditions of Use. We may use the contact details provided and verified by you to reach out to you via call, email or SMS; and
  7. to comply with applicable laws

All Information collected on our Platform is securely stored within our controlled database. The database is stored on servers secured behind security controls such as firewalls. Access to the servers is password- protected and is strictly limited to authorised personnel only. Data in transit is encrypted using SSL/TLS protocol. You are advised to refrain from posting your Information anywhere on the Platform, other than as specifically required by eBullion and in the manner instructed by us through the Platform. Your user account Information and profile are password protected. eBullion will never ask for your password through unsolicited phone calls, emails or other forms of communication. However, if any person, claiming to be an authorized representative of eBullion, contacts you, we request you not to provide any Information to such person and instead immediately contact eBullion as per the contact details provided in this Policy. You agree, confirm and acknowledge that eBullion shall not be liable for any loss or damage of Information provided by you to such persons.

Further, please do not provide or make available any other person's data or Information available to us, without the prior express consent of such persons. If such Information is made available to us by you, it will be deemed that you have the authority and consent to provide us with such Information for our use in accordance with this Policy.

You further consent to us using your Information to communicate with you through calls, emails, SMS, instant messaging applications.

The act of providing Aadhar is voluntary in nature, which will be required for completing your account opening procedure on-line. DigiLocker is a part of the National e-Governance Division under the Ministry of Electronics & Information Technology (MeitY), Government of India. The Digital Aadhaar issued within DigiLocker is the same as the eAadhaar issued by UIDAI (https://eaadhaar.uidai.gov.in). DigiLocker has partnered with UIDAI to make it available automatically to its users when they link their DigiLocker account with Aadhaar. This act of issuing an eAadhaar within Digilocker and subsequently Digilocker sharing the information limited to the above points, is similar to a physical KYC. We only receive information limited to the above points for the purposes of completing KYC of clients online. Based on your consent, we receive and store information limited to (1). The last four digits of the Aadhar; (2) Full Name (3) Date of Birth (4) Gender (5) Address and (6) your Photo.

You hereby represent and warrant to eBullion that:

  1. The Information that you provide to eBullion from time to time is and shall at all times be true, correct, accurate and not misleading in any respect whatsoever .
  2. You have all the rights, permissions, authorisations and consents as may be required to provide Information to eBullion.
  3. The Information provided by you to Ebullion is and shall not be in conflict with or in violation or default of (a) any third party agreement to which you are a party, (b) laws applicable to you, (c) the constitutional documents of the entity that you are authorised to represent on the Platform, or (d) any judgments, orders or decrees which apply to you.

Your Information will primarily be stored in electronic form. However, certain Information may also be stored in physical form. We may enter into agreements with third parties to store or process your Information. These third parties may have their own security standards to safeguard your Information and we will on a commercially reasonable basis require such third parties to adopt reasonable security standards to safeguard your Information.

If you change your mind after opting-in to provide us with or make Information available to us, you may withdraw your consent for the continued collection, use or disclosure of your Information, at any time, by deleting your registration with us on all Platforms.

However, even after deletion of your account, we will retain your Information in accordance with appliable law, for a period no longer than is required for the purpose for which it was collected or as required under any applicable law. However, we may retain Information related to you longer, if we believe in good faith that such retention of your Information may be necessary to prevent any fraud, illegal activity or future abuse or or for other legitimate purposes, including defending ourselves in legal proceedings or enquiries or investigations or claims.

We may collect, use, handle, store or disclose personal Information to third parties such as partner financial institutions including banks, payment gateways, authorized service providers, payment transaction processors, and governmental agencies and authorities, if in good faith we believe that it is reasonably necessary to (a) enforce and secure our Terms and Conditions of Use, (b) comply with applicable laws; (c) detect, investigate, prevent or take action regarding unlawful and illegal activities, technical issues, suspected fraud, potential threat to the safety or security of any person; and /or (d) pursuant to any legal processes and proceedings to which we are made a party or any governmental requests.

We define minors as individuals under the age of 18. This Platform is not intended for the use of minors or for persons who cannot form a legally binding contract under the Indian Contract Act, 1872. eBullion does not knowingly solicit or collect Information from minors. If you are under the age of 18 years then you must use the Platform or Services under the supervision of your parent, legal guardian, or any responsible adult.

We store your Information in India. The hosting facilities for our website is situated in India.

Only the persons authorized by eBullion will have access to your Information. By accepting this Policy, you grant complete and unconditional consent to eBullion for using such Information and sharing the Information with persons or entities affiliated or associated with eBullion, including their respective employees, directors, officers, consultants, contractors, agents, and/or representatives and to each of our respective employees, directors, officers, consultants, contractors, agents, and/or representatives, insofar as reasonably necessary for the purposes as set out in this Policy. It is clarified that all of our rights and obligations under this Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your Information to any of our affiliates, successor entities, or the new owner.

We may also share your Information with third parties to (a) provide you access to our products and Services, (b) assist or facilitate the fulfilment of the sale or purchase requests, (c) assist or facilitate payment on the Platform, (d) assist in providing banking and storage facilities for the products purchased by you, (e) enhance your experience on the Platform, (f) conduct surveys, (g) facilitate our marketing activities, (h) assist in feedback and customer support, (i) analyse data, (j) ensure the security of our Platform, (k) assist with technical operations such as maintaining software, databases and back -up, (l) undertake the know- your customer requirement processes; and (m) undertake, assist or facilitate such other activities related to our products and Services. We will ensure that third parties with whom your Information has been shared undertakes to ensure at least the same level of data protection as being provided by us under this Policy. We will however not be responsible or liable for any action or inaction of such third parties in relation to the use or misuse of your Information for any reason whatsoever. We may also disclose your Information to our insurers and other professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or to defend ourselves in a legal or administrative proceedings.

The Platform may provide links to websites of certain third-party service providers such as payment gateways, other payment transaction processors or data backup service providers, whose services are integrated with our Services or access to third-party websites or other digital properties, including social networking websites. Please note that such third-party service providers or other digital properties are governed by their respective terms of use and privacy policies. For these service providers and other digital properties, we recommend that you read their privacy policies so you can understand the manner in which your Information will be accessed, processed and handled by these providers. In particular, remember that certain providers or other digital properties may be located in or have facilities that are located in a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your Information may become subject to the laws of the jurisdiction(s) in which that service provider is or its facilities are located. Once you leave our Platform or are redirected to a third-party website or application, you are no longer governed by this Policy or our Terms and Conditions of Use and in such circumstances, the privacy policy and terms and conditions of use of such other third-party website will apply. Further, we do not make any warranties and expressly disclaim all warranties express or implied, including without limitation, those of merchantability and fitness for a particular purpose, title or non-infringement with respect to any information or services or products that are available or advertised or sold through these third-party websites.

We reserve the right, at our sole discretion, to change, revise and modify any or all portions of this Policy at any time, with an intimation to you. You are requested to please review the Policy periodically, to remain aware of any changes. Changes and clarifications will take effect immediately upon their posting on the Website. If we make changes to this Policy, we will notify you that it has been updated. Any continued use of the Services shall signify your acceptance of such new or updated Policy, as the case may be. If we are acquired by or merged with another company, your Information may be transferred to the new owners so that we may continue to provide services to you.

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data and your Information. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store your Information. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that your Information will not be intercepted while being transmitted to us over the internet. And, of course, any information you include in a posting to the discussion areas is available to anyone with internet access.

While you are registered with our Platform and anytime within 3 (three) months of you deleting your account on our Platform, you may contact our Grievance and Compliance Officer with respect to any complaints or concerns including those pertaining to breach of Policy or feedback or complaints relating to the Policy, at the following co-ordinates/ contact details of the Grievance and Compliance Officer:

The Grievance and Compliance Officer: Name: Rajiv Ranjan Email: rajiv@ebullion.in
Name of the Company: eBullion Private Limited
    Address: EBULLION PRIVATE LIMITED

When you visit the Website, one or more cookies will be sent to the computer/smartphone or other devices being used by you. Cookies are small files or texts used to store information on browsers. Cookies are used to store and receive identifiers and other information on computers, phones and other devices. Other technologies, including data that we store on your web browser or device, identifiers associated with your device and other software, are used for similar purposes. Cookies enable us to offer Services to you and to understand the information that we receive about you, including information about your use of other websites and apps, whether or not you are registered or logged-in.

We may use Google Analytics and/or a similar service provider or technology to analyse the use of one or more of the Platforms. Google Analytics and other such similar tools that gathers information about the use of the relevant Platform by means of cookies. The information gathered relating to the Platforms is used to create reports about the use of our Platforms. For more information, please review such service provider’s privacy policy available at: their respective websites. To opt out of such services please refer to optout options on their website. Eg; click on https://tools.google.com/dlpage/gaoptout for Google Analytics opt out.

The cookies are either used to improve the quality of the Platform or for storing your preferences as a user, improving search results and tracking user trends. You have the option of disabling cookies via your browser preferences. Most browsers and devices allow you to prevent them from accepting new cookies or alert you when cookies are being sent or disable cookies altogether. Each browser and device is different and manufacturers may change both the settings they make available and how they work at any time; so check the ‘help’ menu of your browser or device to learn how to change your cookie preferences or read the additional information about the controls offered by popular browsers at the links below:

Google chrome: https://support.google.com/chrome/ansWer/95647;

Internet explorer: https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop

Safari: https://support.apple.com/en-ie/guide/safari/sfri11471/mac

Opera: https://blogs.opera.com/news/2015/08/how-to-manage-cookies-in-opera/

Microsoft edge browser: https://support.microsoft.com/en-us/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd

Please note that the above links are as available on November 1, 2021

However, if you disable cookies on your browser, some or all features of the Platform may not function effectively and your use of such features will be limited to such extent.

YOUR RESPONSIBILITY FOR THE INFORMATION YOU PROVIDE

By accessing the Platforms, you may be required to create a username, password and/or provide us with other personally identifiable information. Any Information shared by you with us on any Platform must be kept confidential by you and must not be disclosed to, or shared with, anyone.

The Policy shall be governed and construed in accordance with the laws of India. In the event of any disputes or claims arising out of this Policy the same shall be settled in accordance with the Laws of India. The courts of Mumbai, India shall have exclusive jurisdiction.