Privacy Policy

1. Information We Collect

Information You Provide Us

When you register for an account or interact with our services, you may voluntarily share certain details with us, including but not limited to:

• Identification Information: Your name, mobile number, email address, password, date of birth, gender, and residential address.
• Financial Information: Bank account details, asset values, liabilities, net worth data, and any other financial information entered for the purpose of tracking your net worth.
• Additional Data: Any supplementary information you choose to provide or that we may request to deliver tailored features or support.
• Transactional Information: Financial data including asset and liability details, balances, or transaction history you manually enter. Currency preferences for displaying financial data.

Telemetry Information and Cookies

We may collect non-personal information that does not directly identify you, such as:

• Device and Technical Information: Device information such as IP address, operating system, browser type, and hardware attributes.
• Usage Data: Pages visited, features used, and time spent on the App.

We use cookies and similar technologies for session management, security and fraud prevention. Cookies do not collect Personal Information unless linked with data you have already provided.

Mobile Device Information

When accessing the app via a mobile device, we may collect:

• Location data (if enabled by you) to provide location-based features, such as currency preferences. You may disable location access through your device settings; however, certain features may be limited as a result.
• Device identifiers such as unique device ID or IP address.

User Communications

We may collect and retain information you provide when you engage with us through various communication channels, including:

• Feedback, comments, or interactions with our support channels via email, in-app chat, or chatbot.
• Content shared in any interactive areas of the Platform (if available).
• We collect and store such communications to respond to queries, resolve disputes, improve services, or troubleshoot issues.

AI Assistant Inputs

When you engage with our AI-powered assistant, we may collect and process the text of your queries, preferences, or goal-related inputs to provide contextual responses and enhance your financial planning experience. This information may include financial goals, spending habits, income sources, investment behavior, or similar data points that you choose to share voluntarily.

Goal-Based Planning Data

If you choose to set up financial goals such as retirement, home purchase, or education planning, we collect relevant information such as time horizon, target corpus, risk appetite, and associated financial metrics to personalize projections and insights.

Execution Data

When you choose to execute transactions via linked platforms such as BSE for stocks or MF Central for mutual funds, we may collect transaction-related data such as order IDs, asset types, and execution timestamps from partner APIs or through redirect-based execution workflows. This data is used solely to update your net worth profile and provide a consolidated view of financial activity.

All information you provide to us is deemed to be voluntarily submitted. Pivot.Money by Networth Tracker does not assume responsibility for verifying the authenticity, accuracy, or legality of any information provided by users.

2. How We Use Your Information

We use the information we collect to provide a secure, personalized, and seamless experience on the Platform. Specifically, your data may be used for:

• Providing and improving the net worth tracking and related services you request.
• Customizing your experience, such as displaying data in your preferred currency or generating tailored charts.
• Facilitating conversational assistance and responses through our AI-powered assistant, leveraging data you have provided, preferences, and past interactions.
• Enabling goal-based financial planning and tools such as simulations and progress tracking based on your defined objectives.
• Synchronizing your executed transactions from partner platforms like BSE and MF Central to ensure your net worth dashboard reflects real-time financial activity.
• Ensuring regulatory compliance while transmitting required data to authorized execution partners and intermediaries for completing your financial transactions.
• Resolving disputes, troubleshooting issues, and ensuring the Platform's security and integrity.
• Processing payments or validating financial data (if applicable).
• Sending you updates, reminders, or promotional materials about our services (with an option to opt out).
• Detecting, preventing, or investigating errors, fraud, or prohibited activities.
• Enforcing our Terms and Conditions and communicating policy changes.
• Responding to your inquiries or comments.
• Analyzing usage trends to enhance Platform performance and user experience.
• Contacting you for feedback or to offer new features.
• Aggregating anonymized information from registered users to perform market research, project planning, product development, troubleshooting, and marketing purposes.
• Using cloud-based software tools for business functions including maintaining databases, processing communications, and performing marketing and sales analytics.

We may use your IP address and device-related information to diagnose technical problems, server issues, administer the Platform, or gather broad demographic data. Telemetry Information such as anonymized or aggregated data may be used, stored, processed, or shared for any purpose unless prohibited by applicable law.

3. User Rights

We are committed to respecting your privacy and empowering you with control over your Personal Information. Subject to applicable laws and certain limitations, you have the following rights:

• Right of Access: You may request a copy of your Personal Information in a structured, commonly used, and machine-readable format. Where technically feasible, you may also request that we transfer this data to another data controller.
• Right to Rectification: You have the right to request correction of any inaccurate, outdated, or incomplete Personal Information. Please contact us at support@pivotmoney.app in writing to initiate the correction process.
• Right to Information: You may inquire about our data handling practices, including the categories of data collected, the purpose of processing, and any third parties with whom the data is shared.
• Right to Object: You may object to the processing of your data when such processing is based on legitimate interests, direct marketing, or statistical and research purposes.
• Right to Withdraw Consent: Where data processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
• Right to Erasure: You may request deletion of your Personal Information. This right is subject to certain legal and contractual obligations that may require us to retain some data.

To exercise these rights, contact our grievance officer (details in Section 10).

4. Sharing of Information

We value your trust and take your privacy seriously. We only share your Personal Information in limited circumstances, and always in accordance with this Privacy Policy and applicable data protection laws. Your information may be shared as follows:

• Affiliates and Subsidiaries: We may share your information with our group companies, affiliates, or subsidiaries to facilitate seamless delivery of services. These entities are bound by this Privacy Policy or equivalent privacy obligations.
• Service Providers: We engage trusted third-party service providers to support our operations including cloud storage, data analytics, customer support, and payment processors. These providers are contractually bound by confidentiality and data protection obligations.
• Execution Partners: If you initiate investment or redemption transactions through third-party execution platforms such as BSE or MF Central, we may securely share required identifiers such as PAN, folio number, or transaction request details to facilitate your instructions.
• AI Processing Infrastructure: Inputs submitted via the AI assistant may be processed using secure AI infrastructure solely for delivering real-time, context-aware responses. No personal identifiers are stored beyond the session unless required for specific features like goal tracking.
• Legal Compliance: We may disclose your information if required by law, regulation, legal process, or governmental request. This includes situations where disclosure is necessary to:
  • Comply with applicable legal obligations
  • Enforce our Terms and Conditions
  • Protect the rights, property, or safety of Networth Tracker, our users, or the public
• Emergency Situations: In urgent or emergency situations, we may share your data when necessary to protect life, personal safety, or significant property interests.
• Business Transfers: If we are involved in a merger, acquisition, sale of assets, or corporate restructuring, your Personal Information may be transferred as part of that transaction, handled in accordance with applicable laws and subject to this Privacy Policy.

We do not share your goal-setting information, transaction details, or AI-powered assistant conversations with any third party for advertising or resale purposes, without your explicit consent.

We are committed to protecting your privacy and ensuring compliance with applicable laws, including the Digital Personal Data Protection Act, 2023 ("DPDP Act").

5. Retention and Deletion

We retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law and regulations. We periodically review the data to ensure it remains accurate, relevant, and up-to-date.

If you choose to delete your account or withdraw your consent, we will take reasonable steps to delete your Personal Information from our active records. However, certain data may be retained under specific circumstances, including:

• You maintain active connections with other services via our Platform.
• We need the data to provide requested services.
• Legal obligations require retention.
• Data is needed to prevent fraud, support users, or investigate misconduct.
• Data is anonymized and cannot be re-identified.
• You explicitly agree to extended retention.
• Anonymized data may be retained for statistical and analytical purposes, for example to track platform usage metrics, without identifying individual users.

6. Third-Party Service Partners

For the provision of Services, Pivot.Money by Networth Tracker may utilise third-party service partners. The use and operation of any integrated services will be additionally governed by the relevant service terms of the respective Service Partners. Pivot.Money by Networth Tracker shall not be liable for any penalties, loss or damage incurred due to the negligence or actions of any Service Partner. The Service Fulfilment Partners are Google Analytics, Amazon Web Services (Cloud), and Firebase.

You acknowledge and agree that, for the provision of Services:

• Pivot.Money by Networth Tracker shall carry out all activities required to fulfil its regulatory obligations for the provision of Services.
• Your access to our Services is associated with a username and password. You are solely responsible for the security of your Login Credentials. Pivot.Money by Networth Tracker shall not be held liable for unauthorized instructions placed using your credentials due to a security breach on your part.
• Pivot.Money by Networth Tracker may utilise third-party vendors for support in provision of Services. Vendors include Dashboard Account Aggregation Services Private Limited (SAAFE), BSE Star MF Mutual Fund Platform, and MF Central.
• Pivot.Money by Networth Tracker, or its Vendors, may:
  • Contact you on issues relating to provision of Services.
  • Communicate with Service Partners on your behalf for financial or non-financial transactions.
  • Record all your interactions including phone calls, chats, conversations, and emails for legal compliance, security, employee training, and other lawful purposes.
• Any graphical representations, recommendations, feedback, and reviews provided on the investment platform are in no way a guarantee for the performance of securities, mutual funds, and other financial products.
• Other than as expressly set out in this Agreement, neither Pivot.Money by Networth Tracker nor any of its Service Partners make any specific promises about the Services provided. The Services are provided 'as is'.
• Your bank may charge you a fee for facilitating transactions, or for failing to maintain sufficient balance to make an investment. Pivot.Money by Networth Tracker does not levy nor receive those charges.

7. Security Measures

At Pivot.Money by Networth Tracker, we implement industry-standard safeguards to protect your data from loss, misuse, unauthorized access, disclosure, alteration, or destruction, in compliance with applicable laws including section 43A of the Information Technology Act, 2000. Key security measures include:

• Secure servers for data transmission and storage.
• Encryption for sensitive data such as financial information.
• Access controls to limit data exposure.
• Encryption of data at rest and during transit.
• IAM and Key Management Services to limit access to your data.

While we take extensive precautions to safeguard your data, no system can be entirely secure. We cannot guarantee absolute protection against breaches resulting from hacking, viruses, or other events outside of our control. As a user, you are responsible for securing your account credentials and ensuring they are not shared with others.

If you suspect any unauthorized access or encounter a security breach, we encourage you to notify us immediately. In the event of a data breach, we will inform you and, if required by law, notify relevant authorities.

You agree not to upload, share, or transmit any content that:

• Belongs to others without permission.
• Is obscene, harmful, or illegal.
• Infringes intellectual property rights.
• Misleads, impersonates, or spreads misinformation.
• Threatens security, public order, or national integrity.
• Contains viruses or harmful code.

8. Your Consent

By using the Platform or creating an account, you consent to this Policy's terms.

9. Withdrawal and Rectification

You may:

• Review or update your information by contacting us.
• Withdraw consent for data processing by emailing our grievance officer.
• Request account deletion, subject to legal or contractual obligations.

Please provide accurate and complete information to ensure uninterrupted services.

We may update this Policy from time to time. If we make changes, your continued use of the Platform means you accept the updates. We recommend checking this Policy occasionally to stay informed about any changes.

10. Contact Us

For questions, requests, or complaints about data processing, contact our grievance officer: Mr. Shashin Koradia

Email: support@pivotmoney.app

We aim to address grievances promptly.

11. Governing Law

This Policy is governed by the laws of India, with exclusive jurisdiction in the courts of Mumbai.