Privacy Policy

Ottenn Fintech Private Limited (CIN NO-U66190GJ2024PTC151254), a private limited company having its registered office at Maruti Nagar -B-25 (RAM), Ravapar Road, Morbi MDG, Rajkot, Morbi, Gujarat, India, 363641, its affiliates and group entities, together referred to as "Company", "We", "Us", or "Our", which owns and operates the website www.ottenn.com and/or the mobile application 'Ottenn' (collectively referred to as the “Platform”), is committed to protecting Your privacy and the information that You share while using the Platform. We value the trust You place in Us. That’s why, We maintain the highest security standards for securing the transactions and Your information.

This Privacy Policy specifies the manner in which personal data and other information is collected, received, stored, processed, disclosed, transferred, dealt with, or otherwise handled by the Company. This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party (excluding the Company or its affiliates set out in paragraph 3 below) through the Platform, and any Third-Party Sites that You access or use in connection with the services offered on the Platform.

Please read the Privacy Policy carefully prior to using or registering on the Platform or accessing/availing the services on the Platform, including inter alia in relation to mutual fund distribution, stock broking services, investment advisory services, and KRA/KYC verification (“Services”).

By visiting the Platform, You (“You” or “Your”), accept and agree to be bound by the terms and conditions of this Privacy Policy (“Privacy Policy”). This Privacy Policy is incorporated into and subject to the terms of use of the Platform (“Terms”) and shall be read harmoniously and in conjunction with the Terms.

Collection of Information

We collect Personal Information (as defined below) from You when You register or set up an account with Us on the Platform. While You can browse certain sections of the Platform without being a registered member, to access and avail specific Services on the Platform (such as investing in funds), You are required to register with Us

Collection of Personal Information

This Privacy Policy applies to the collection and use of the following

Personal Information You Provide Voluntarily :
When you register on Our Platform to use Our Services, you may provide personal details such as :

• Mobile number
• Email address
• Password
• Date of birth
• Gender
• Permanent Account Number (PAN)
• Signature
• Marital status
• Nominee details

Additionally, we may ask for financial information, such as :

• Billing address
• Bank account details
• Credit card number and expiration date

Other payment-related information You may also be asked for additional information on a case-to-case basis. All information provided is deemed to be given voluntarily and without coercion. The Company is not responsible for the authenticity or genuineness of the information provided, nor will the Company verify any information you provide.

Information Retrieved from Third Parties :
We may retrieve certain details from third-party sources, including Know Your Customer (KYC) Registration Agencies (KRA), such as :

• Your name
• KYC details and status
• Father’s name
• Occupation
• Address and related documents

Transaction Information :
If you choose to invest through the Platform, we will collect information about your transactions, including :

• Transaction status
• Transaction details
• Investment behavior

Device and Location Information :
When you download and use the Platform on your mobile device, we may collect :

• Your location
• Your IP address

Mobile device information (including a unique identifier number) This data helps provide you with location-based Services, such as search results and personalized content. You may disable location-tracking features at any time, though this may affect your experience on the Platform.

Non-Personal Information :
In addition to Personal Information, we may collect non-personal data such as :

• Internet protocol (IP) address
• Web request
• Operating system
• Browser type
• Internet service provider

URLs, aggregate user data, cookie information, etc. This information is not tied to your identity and is collected to analyze user trends, web traffic, and improve Platform services. We use "cookies" to track user interactions with the Platform, improve your experience, and measure promotional effectiveness. Cookies may be permanent or temporary (session cookies), and you can opt to disable them through your browser. However, some features of the Platform may not work properly if cookies are disabled.

Purpose of Collecting Information :
Our primary objective in collecting this data is to provide you with a safe, efficient, and customized experience on the Platform. The information helps us to offer Services and features tailored to your needs, and to enhance your overall experience. We may also use aggregated, non-personal information to improve the Platform and to perform internal research on user demographics, interests, and behavior.

Use of Your Information

We use your Personal Information and other Non-Personal Information for the following purposes :

To provide and enhance the Services on the Platform that you request.

1. To resolve disputes and troubleshoot issues.
2. To ensure a safe environment on the Platform, protecting its security and integrity, and safeguarding the users.
3. To collect payments from you for the Services.
4. To inform you about online and offline offers, products, services, and updates.
5. To personalize your experience on the Platform and share marketing materials with you.
6. To detect, prevent, and protect against errors, fraud, and other unlawful activities on the Platform.
7. To enforce and communicate our terms and conditions.
8. To process and fulfill your requests for Services, or respond to your comments and queries on the Platform.
9. To contact you as needed.
10. To enable our business partners and associates to present customized messages to you.
11. To notify you of important updates or changes in the Services, Platform usage, and the terms and policies governing your relationship with the Company and its affiliates.
12. For any other purpose after obtaining your consent at the time of collection.
13. Additionally, you specifically consent to us collecting, storing, processing, transferring, and sharing your information (including Personal Information) with third parties such as entities registered with applicable laws like the Securities Exchange Board of India, National Stock Exchange of India Limited/BSE Limited, Central Registry of Securitisation Asset Reconstruction and Security Interest of India (CERSAI), payment gateways, collecting banks, KRAs, etc., solely for processing your transaction requests related to the Services.

We may also use your IP address to diagnose server issues, resolve problems, and administer the Platform. Your IP address helps us identify you and gather general demographic information.

From time to time, we may ask you to participate in optional online surveys, which may collect your contact and demographic details (e.g., zip code, age, income level). We use this information to customize your experience on the Platform, offering content and services that align with your preferences. While we may send you promotional emails based on your preferences, we provide the option to opt-out. However, opting out of promotional emails will not prevent us from sending you important non-promotional emails related to your account or the Services.

Unless you explicitly give us consent, we will not share your Personal Information with other users of the Platform.

Sharing of Information

We may share your Personal Information and/or Non-Personal Information with our affiliates, including Ottenn Fintech Private Limited ("Ottenn"), to enable them to provide Services to you through the Platform. Please note that all information shared with or made available to our affiliates will be governed by the terms of this Privacy Policy.

In addition to the Personal Information, and in order to provide the Services, Ottenn may also collect your Aadhaar, fingerprint details, and signature solely for completing account opening procedures and authenticating your transactions on the Platform. The provision of your Aadhaar is voluntary. Ottenn hereby agrees and acknowledges that it will collect, use, and store such details in compliance with applicable laws and this Privacy Policy.

We may also disclose your Personal Information to third-party vendors, consultants, and other service providers who work for the Company. These parties are bound by contractual obligations to maintain the confidentiality of your information and use it only for the purposes for which we disclose it to them. Such disclosures may be required for us to provide you access to our Services, process payments, validate bank account details, assist in marketing and advertising activities, perform auditing or data analysis, or prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services. We do not disclose your Personal Information to third parties for their marketing or advertising purposes without your explicit consent.

Disclosure of Information

The Company may disclose your information to the extent necessary under the following circumstances:

Compliance with Laws :

To comply with applicable laws, respond to lawful requests, and legal processes.

1. Protection of Rights : To protect the rights and property of the Company, our users, and others, including enforcing the Terms and Conditions.
2. Emergency Situations : In emergencies, to protect the personal safety and assets of the Company, users, or any individual.
3. In such cases : The Company is not obligated to inform you or seek your approval or consent.

Additionally, we and our affiliates may, in accordance with applicable laws, share, transfer, or assign all of your Personal Information and other details with other business entities in the event of a merger, sale, reorganization, amalgamation, joint ventures, assignment, restructuring, or the transfer of all or part of our business.

Connecting Your Email Account

You may choose to provide explicit consent to connect your email account(s) with your account on the Platform by clicking on the authentication email sent by the Company to your registered email address. Each time, you will be expressly asked whether you want to integrate your email account with your Platform account. Once connected, the Platform will securely access and analyze your emails, including attachments from CAMS or Karvy’s Consolidated Account Statement (CAS), to track and populate your investment details and history in one place.

This integration will be used solely to improve your experience with the Platform and to consolidate your investment details. We assure you that the Company will not use or transfer any data obtained through this integration to third parties for advertisement purposes, including personalized or interest-based advertising. We further undertake that our employees, agents, contractors, and successors will comply with all applicable laws.

You can choose to disconnect your email account from the Platform at any time by managing the connection through the Platform’s settings. For instance, Google Mail’s permission settings can be found at: myaccount.google.com/permissions.

Third-Party Sites and Information Collection

The Platform may link you to third-party sites ("Third-Party Sites") that may collect your Personal Information, such as your IP address, browser specifications, or operating system. The Company is not responsible for the security or privacy practices of these Third-Party Sites, nor their content. Additionally, these Third-Party Sites may use "cookies" or other similar devices, which are not controlled by the Platform.

These third-party service providers and Third-Party Sites may have their own privacy policies governing how your information is stored and used. This Privacy Policy does not apply to information collected by these third parties. We recommend that you review the privacy policy of any Third-Party Sites you visit to understand how they safeguard your information.

The Platform uses third-party advertising companies to serve ads when you visit the Platform. These companies may use non-personal information (such as your visits to the Platform and Third-Party Sites) to provide advertisements for goods and services of interest to you. You agree and acknowledge that the Company is not responsible for information published in search results or by any Third-Party Sites.

Security Measures and Precautions

Our Platform implements reasonable security measures to protect your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction, in accordance with applicable laws. When you change or access your account or any related information on the Platform, we provide the use of a secure server.

However, we cannot guarantee the absolute security of any information you transmit to the Company, nor can we ensure that your Personal Information or Non-Personal Information will not be accessed, disclosed, altered, or destroyed due to a breach of security measures. You are responsible for ensuring that you take adequate physical, managerial, and technical safeguards on your end to maintain the integrity and security of your data, including your Personal Information, while accessing or using the Platform.

When making payments on or through the Platform, your payment information will be protected by encryption technology. By using the Platform, you expressly consent to the sharing of your information with third-party service providers, including payment gateways, for payment processing and management of your payment-related data. While we take steps to protect this information, we cannot guarantee the security of any transmissions or that unauthorized third parties will never bypass our security measures or those of our third-party providers.

The Company is not liable for any disclosure of your information due to errors in transmission, unauthorized third-party access, or any other causes beyond our control. You also play an essential role in keeping your personal information secure. Please do not share your personal or security information related to your account with anyone.

While we have taken reasonable steps to protect your privacy in connection with your use of the Platform, the Company is not liable for any unauthorized or unlawful disclosure of your information by third parties who are not under our control.

Data Retention - Deleted Account

You may request us to delete your information or revoke the consent to access or opt out of processing your application by submitting a request for account deletion through the Ottenn mobile app via the profile section. On submitting a request to delete Your account, you confirm/understand that :

• You have no outstanding credit facility availed on the Ottenn platform.
• You have no pending or potential grievances in relation to any of your previous dealings with Us.
• Your account will be permanently deleted. We will not be able to reactivate your account.
• You will receive no further communications from Ottenn. You however understand that We will be required to or retain, and accordingly use and disclose any specific data if required by law, rule, regulation, law, enforcement, governmental official, legal, or regulatory authorities and / or to such other statutory bodies who have appropriate authorisation or for the purposes of completing any legal obligations or for audit requirements. We will not retain your Personal Information(including sensitive personal data) for longer than is required for the purpose for which the information may lawfully be used.

Your Consent and Changes to Privacy Policy

Your Consent :

By accessing the Platform or creating an account to use the Services offered, you consent to the terms of this Privacy Policy.

Withdrawal of Consent :

You have the right to withdraw your consent at any time. To withdraw, you must send a written request to support@ottenn.com. If you choose to withdraw your consent or do not provide your consent initially, we kindly ask that you refrain from accessing the Platform or using the Services. In such cases, the Company may, at its discretion, delete or anonymize your personal information.

Changes to Privacy Policy :

We reserve the right to update, modify, or revise this Privacy Policy at any time, without prior notice. Any updates will take effect immediately. You are encouraged to review this Privacy Policy periodically. You can identify if changes have been made by referring to the "Last Updated" section above. Your continued use of the Platform after any updates signifies your acceptance of the revised Privacy Policy and your agreement to be bound by its terms.

-If you have any grievances regarding the Platform, please contact our Grievance Officer whose details are provided below:
Email: support@ottenn.com

Questions?

If you have any questions regarding this Privacy Policy, please feel free to reach out to us at support@ottenn.com.