Privacy Policy
This Privacy Policy explains how we collect, use, store, and share your Personal Data. By using Pivot Money App/Website (“Platform”), you consent to practices described here. If you disagree, do not use the Platform.
1. Who We Are & Why This Policy Matters
We are a Data Fiduciary under the Digital Personal Data Protection Act, 2023.
We are also SEBI registered Investment Adviser, AMFI registered MF Distributor, and ReBIT certified FIU in the Account Aggregator ecosystem.
Each service has specific data rules, and this Policy covers all of them.
2. What Personal Data We Collect
Sensitive Personal Data: We do not collect biometric, health, caste, or religion data unless required by law.
3. Account Aggregator Specific Disclosures
- Consent based: We fetch data only after you give explicit consent on the AA network.
- Purpose limitation: Data is used only for the purpose shown in consent, such as Net Worth Display, Risk Profiling, and Financial Planning.
- Data minimisation: We request only the data fields needed for the purpose and specific date range.
- No storage of raw data: Raw AA data is processed and deleted after the purpose is served, up to 6 months. Only derived insights are stored.
- Consent artefact: We store consent ID, timestamp, and purpose for 6 years as per RBI. You can view or revoke consents in App > Settings > AA Consents.
- No liability for FIP data: Accuracy of bank or MF data is the responsibility of the FIP. We display data as received.
4. How We Use Your Data
- To provide services: KYC for MF, execute transactions, provide advice, show net worth, and process payments.
- Legal compliance: Report to SEBI, RBI, FIU-IND, CKYC, KRA, IT Dept, and AMFI as required.
- Risk and fraud: Monitor suspicious transactions, comply with PMLA, and file STR to FIU-IND.
- Service improvement: Analytics and debugging using anonymised or aggregated data.
- Communication: Transaction alerts, service updates, and regulatory disclosures. No marketing SMS/email without opt-in consent.
We do not sell your data. We do not use AA data for cross-selling unless you consent separately.
5. How We Share Your Data
All data processors sign agreement under Section 8(2) of the DPDP Act, and we remain liable for their compliance.
No Cross-Border Transfer: All Personal Data is stored in India. If transfer is needed, we will take your consent and ensure a DPDP-compliant country.
6. Your Rights Under DPDP Act, 2023
You can exercise these via App > Profile > Privacy or email Compliance@pivotmoney.app.
- Right to Access: Get summary of your Personal Data and processing activities.
- Right to Correction / Erasure: Update KYC, delete account. We may retain data for 5–8 years per SEBI / PMLA / RBI.
- Right of Grievance Redressal: Response within 7 days.
- Right to Nominate: Nominate a person to exercise rights if you are deceased or incapacitated.
- Right to Withdraw Consent: For AA and advisory. Withdrawal does not affect past processing. Services dependent on data will stop.
Grievance Officer / Data Protection Officer:
Name: Jash Koradia
Email: Compliance@pivotmoney.app
Address: As above
Response TAT: 7 days. If unresolved, escalate to the Data Protection Board of India.
7. Data Security
- Encryption: AES-256 at rest and TLS 1.3 in transit. AA data per ReBIT specs.
- Access control: Role-based access, MFA, and audit logs.
- Certifications: ISO 27001 and Cert-in annual audit for PA and FIU.
- Breach notification: If a breach occurs, we notify you and the Data Protection Board within 72 hours as per DPDP Act Sec 9(5).
Despite safeguards, no system is 100% secure. Keep your password and OTP confidential.
8. Data Retention
After expiry, data is deleted or anonymised except where retention is needed for legal disputes.
9. Children’s Data
We do not knowingly collect data of persons below 18 years.
Minor accounts need guardian consent and KYC per SEBI rules.
10. Cookies & Tracking
- We use essential cookies for login and security.
- Analytics cookies are used only with consent. You can disable them via browser settings.
- We do not use third-party advertising cookies.
11. Changes To This Policy
- We may update this Policy, and the “Last Updated” date will change.
- Material changes are notified via app or email 15 days prior.
- Continued use means acceptance of the updated Policy.
12. SEBI RIA & RBI PA Specific Disclosures
- SEBI: Advisory data is used only for suitability, and records are maintained for 5 years for inspection.
- RBI PA: Payment data is stored per RBI guidelines, and we are liable for data breach of card data.
- FIU-IND: We may file Suspicious Transaction Reports without informing you, as per PMLA Sec 12.
13. Contact Us
For questions or rights requests, email Compliance@pivotmoney.app.
Post: Data Protection Officer, Networth Tracker Solutions Pvt Ltd, Mumbai – 400069
SEBI SCORES: https://scores.gov.in for advisory complaints.
RBI CMS: https://cms.rbi.org.in for payment complaints.
Annexure 1 – Consent Language Shown In App
- I consent to Pivot Money fetching my financial data via Account Aggregator for NetWorth Tracking and Risk Profiling. I understand I can revoke anytime.
- I consent to Pivot Money using my KYC data for SEBI compliance and MF transactions.
- I have read the Privacy Policy and Terms.
