PRIVACY POLICY

I. Policy & Purpose
This privacy policy (“Privacy Policy” ) adopted by Pavan Kumar Manchiraju (hereinafter referred to as “We” / “Our” / “Us) governs the collection, use and transfer of any information capable of identifying a person (“Personal Information”) of individuals accessed or shared with Us by virtue of use or access of Our mobile application, or Our website ( https://www.hubridgeadvisors.com/) (referred to as the “Platform”). Unless specified otherwise, this Privacy Policy applies only to the Platform and services, features, software, and functionalities offered by Us, via the Platform.

For the purposes of this Privacy Policy, “Sensitive Personal Data or Information” or “Sensitive Information” means Personal Information, that consists of the (i) password, (ii) financial information, such as bank account, debit or credit card details, (iii) physical, psychological and mental health condition, (iv) sexual orientation, (v) medical records and history, (vi) biometric information, (vii) official identifier, (viii) sex life, (ix) genetic data, (x) transgender status, (xi) intersex status, (xii) caste or tribe (xiii) religious or political belief or affiliation, (xiv) any detail relating to the above as provided to the body corporate for providing a service, and (xv) any of the information received under each of the aforesaid heads by the body corporate for processing, or to be stored or processed under a lawful contract.

This Privacy Policy incorporates the requirements under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and the Personal Data Protection Bill.

II. Our Business & Policy Applicability
By accessing the Platform, You consent to be bound by this Privacy Policy and are accepting the measures, protocols and practices involving the collection, use and transfer of Personal Information collected from You, as set out herein below.

This Privacy Policy does not apply to mobile applications or websites which are not owned or controlled by Us, including third party links and applications with which You may interact while using the Platform. We will not assume any liability for any harm caused to You by accessing any third party websites or links advertised on the Platform.

III. Collection & Use of Information

A. Personal Information Collected When You access the Platform for certain activities or to avail Our services, we may ask You to provide Personal Information about yourself, such as:

DATA COLLECTED	PURPOSE
Name	Creation of account and to personalise communications to you
Email Address	Creation of account/ verification of identity and to send updates and communication we think is relevant to you
Phone Number	Verification of identity & delivery of alerts and updates
Address	Generation of invoice, delivery of physical copies of our research and marketing material

While most information we collect can be shared at the discretion of the Users, some Personal Information (an indicative list of which is set out above) is required to be shared to enable the User to access certain services provided on the Platform. If You do not provide the information required by Us to provide you with a specific service or feature, You will not be able to access such service or feature of the Platform.

B. User Supplied Data
If You send us personal correspondence, such as emails or letters, or if other Users or third parties send us correspondence about Your activities on the Platform, we may collect such information into a file specific to you
Upon contacting Us, We may also use Your contact information for delivery of recommendations and other services subscribed by You from the Platform. You may opt out of receiving any non-essential communications from us by contacting Our Grievance Officer (defined below).

C. Sensitive Personal Data or Information Collected
Please note that We shall always take your express consent before collecting any Sensitive Personal Data or Information.
We are committed to keeping all such Sensitive Personal Data or Information safe at all times and ensure that such data/information is only transacted over secure sites that are digitally encrypted, and provide the highest possible degree of care available under the technology presently in use. We will not use Your Sensitive Personal Data or Information for any purpose other than for such specific purposes as you have expressly consented to its use.
Upon registering on the Platform, You may from time to time choose to provide details of the securities owned by You, the number of securities held and details of your broker which is classified as Sensitive Personal Data or Information. Such payment data may need to be retained only within India to comply with directives of the Reserve Bank of India that apply to the payment service providers we engage to provide the services.
Where we permit any third parties to collect and use your Sensitive Personal Information, we shall (i) ensure that such third parties maintain the same security standards that are adhered to by us for the protection of your Sensitive Personal Information and (ii) take reasonable measures to ensure that the third parties do not disclose the Sensitive Personal Information unless such disclosure has been expressly consented to by you.

D. Non-Personal / Aggregated Data
Apart from the information You provide to us, we may also collect information related to Your browser, internet protocol address, and browser history when using the Platform. We use this information to understand Users’ demographics, interests and behaviour to better understand, protect and serve our users. This information is compiled and analyzed on an aggregated basis.

IV. Storage & Security

All information provided by You is stored and retained on secure servers located in Noida, India. We maintain managerial, technical, operational, and physical security practices and procedures to protect data from misuse and unauthorized access, and maintain the accuracy of data (“Security Practices”).

Such Security Practice involves measures including, but not limited to encryption, firewalls, password protection, limitation of access to specified personnel on a need to know basis, de-identification and encryption and other physical security measures to guard against unauthorized access to the server and systems and information residing on such server and systems. Our Security Practice protects against unauthorized access to, or unauthorized alteration, disclosure or destruction of the information. Our Security Practices contains are commensurate with the information assets being protected and with the nature of the business. By using the Platform, you accept that the Security Practice and procedures mentioned above, which are designed to protect the information provided by You, are reasonable.

We have deployed appropriate physical, electronic, and managerial procedures required under the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, to safeguard and help prevent unauthorized access, maintain data security, and avoid loss of User information. However, transacting over the internet has inherent risks and absolute security of data in the online sphere cannot be guaranteed, therefore, we do not assume any responsibility for any transmission of Your information which You do at Your own risk and/or for disclosure of Your information due to errors in transmission and/or unauthorized acts of third parties.

V. Data Transfers & Disclosures

We will not disclose or transfer any of Your Personal Information or Sensitive Personal Data or Information to any third parties except as explicitly provided in this Policy or where we have Your consent to do so. We will only share Your Personal Information or Sensitive Personal Data or Information with third parties in the following circumstances:
i. Provision of Services:Where any service requested by You involves a third party, such information, as is reasonably necessary for us to carry out a service request involving such third party, may be shared with the third party. We may also engage with other entities to perform functions including but not limited to analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. Such companies shall be granted access to the Personal Information needed to perform their functions and include:

We take efforts to ensure that any agent or third party that we engage comply with the same security standards as we follow for the protection of your Personal Information and Sensitive Personal Data or Information in the our custody.
ii. Law Enforcement:We may also use and disclose the information You provide as we believe to be necessary or appropriate: (a) under applicable law, including laws outside Your country of residence; (b) to comply with investigations or legal process; (c) to respond to requests from public and government authorities, including authorities outside Your country of residence; (d) to enforce Our Terms and Conditions ; (e) to defend Our business, or those of any of Our affiliates from third claims; (f) to protect Our rights, privacy, safety or property, and/or that of Our affiliates, You or others; and (g) to allow us to pursue available remedies in law or equity to limit damages that we may sustain
iii. Change in control:We may also share Your information with third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of Our business, or merge with, acquire, or form a joint venture with, such third party; or (b) sell or transfer any of the our businesses or any of its assets, in which case the information we hold about You may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

VI. YOUR RIGHTS

We do not keep Your data for longer than is necessary unless we are required to do so under applicable law. We will use Your Personal Information only for so long as is necessary:
i. to achieve the purposes that have been specifically identified in this Privacy Policy or such purposes as have been identified in any agreement entered into with you;
ii. as required by applicable laws and regulations, or as may be required for evidentiary purposes;
iii. as deemed necessary for tax, fraud control, or mitigation, and to conduct a defence in relation to any disputes or claims whether potential or actual (taking into account statute of limitations under applicable laws).
You can review, modify, and delete the information You have provided to us at any time by accessing the Platform and/or withdraw Your consent from allowing us to collect, process or transfer Your information by contacting Our Grievance Officer (See Section VII below). Please note that if You withdraw Your consent, we may be constrained to withdraw those features, functionalities, services etc. which cannot be provided, without the information You seek to withdraw consent for, or delete from our records. Please note that your requests with respect to your data shall not be complied with if it adversely affects another user, or prejudices such user’s rights.
Your right to withdraw consent relates to any further collection or processing, of your Sensitive Data, however such withdrawal of consent shall not: (i) be retrospective or require the deletion of records required for statutory purposes; or (ii) operate where required for the discharge of ongoing contractual obligations unless the contract under which the Sensitive Data is required to be collected is also terminated with the request for withdrawal of consent to collect such Sensitive Data.
Your data will be erased/deleted when it has served the purpose for which it was being collected and is no longer necessary, where consent has been withdrawn, or where retention of such data is contrary to or prohibited by applicable law. You have the right to data portability, i.e. you have the right to receive a copy of your personal data in a commonly used and structured, machine-readable format and have it transferred to another service provider or third party after paying us a fee which shall be communicated upon your request.

VII. GRIEVANCE REDRESSAL
In respect of the Personal Information or Sensitive Personal Data or Information which you have provided to us (“Collected Information”), should You wish to (i) request deletion of the Collected Information You have provided to us, from our records, (ii) correct or update the Collected Information, (iii) raise any queries or concerns regarding the purpose of retention, end-use(s) of the Collected Information, or (iv) report a breach of this Privacy Policy, please contact Our grievance officer, Pavan Manchiraki (“Grievance Officer”) at [email protected].
Our Grievance Officer is accessible between 9 AM to 6 PM on weekdays (except public holidays) and will address Your queries or grievances within one month from the date of receipt of such queries or grievances
To the extent You are exercising any of Your rights under applicable law, we will respond as soon as possible, and in any event within 30 days or in accordance with the timeframe permitted under applicable law. You have the right to file a complaint with the Data Protection Authority once constituted, against the refusal to hear a complaint or dissatisfaction in the manner in which the complaint was resolved. We may seek certain information from You (such as Your name and registered contact number or email address) during the grievance redressal or feedback process in order to verify Your identity and establish secure modes of correspondence.
Kindly note that in such the event that you wish to withdraw your consent for us to collect, retain, use, or process your Collected Information, You may not be able to take full advantage of the entire scope of features and services offered to You which rely on such Collected Information, and we reserve the right not to provide such services that require the Collected Information to be supplied to us.

VIII. UPDATES
From time to time, we may update this Privacy Policy. Any changes will become effective when we post the revised Privacy Policy on the Platform. Your continued use of the Platform following these changes means that You accept the revised Privacy Policy, as amended. You are encouraged to review this Privacy Policy from time to time.