Privacy Policy

Effective Date: 1st July, 2025

Pivot.Money by Networth Tracker Solution Private Limited (the "Company", "Networth Tracker", "us", "we", or "our") is the owner and operator of the Whole - Pivot.Money by Networth Tracker platform (the "Platform") along with any associated services, features, or content offered through it (collectively, the "Platform"). This Privacy Policy (the "Policy") informs you and other users of the Platform (together the "Users") about how we collect, use, store, and disclose your personal data when you access or use the Platform. It also outlines the choices and rights available to you regarding your personal information.

As part of our services, we may provide financial or investment-related advisory through the Platform, over the phone, via email, or through any other mode of communication, as deemed appropriate based on your preferences and our operational capabilities.

By using and accessing the Platform, you agree to the collection and use of your information in accordance with this Policy. Unless otherwise defined herein, terms used in this Policy have the same meanings as in our Terms and Conditions.

At Networth Tracker, your privacy is our highest priority. Networth Tracker is committed to protecting the information and privacy of all individuals, customers, and others who use our App or engage with our services. Our mission is to be fully transparent about what data we collect, how we use it, and under what circumstances it may be shared.

We value the trust you place in us, and to uphold that trust, we are guided by the following core privacy principles:

• No Unauthorized Sharing: We do not share, rent, trade, or sell your Personal Information to third parties, except as explicitly outlined in this Privacy Policy. "Personal Information" refers to any information, including personally identifiable or sensitive personal data, that relates to you and, alone or in combination with other available information, can identify you.
• No Contact Sharing without Consent: We do not disclose your contact information with other users of the Platform without your consent.
• Secure by Design: All Personal Information you provide is protected using security protocols and encryption technologies to ensure confidentiality and integrity.

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: Identification details such as your name, mobile number, email address, password, date of birth, gender, and residential address.
• Financial Information: Financial details such as 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 (collectively referred to as "Personal Information").
• Transactional Information: To support our core features like net worth tracking, we may collect 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 (e.g., IP address, operating system, browser type, hardware attributes).
• Usage Data: Usage data (e.g., pages visited, features used, 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 (e.g., 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 but not limited to:

• Provide feedback, post comments, or interact with our support channels (e.g., via email, in-app chat, or chatbot).
• Share content in any interactive areas of the Platform (if available).
• We collect and store such communications ("User 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 (e.g., retirement, home purchase, 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 or such other platform as we may choose from time to time), we may collect transaction-related data (e.g., order IDs, asset types, 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—including Personal Information, Non-Personal Information, Transactional Information, and User Communications—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 and shall not be held liable for any consequences arising from misrepresentations, fraudulent submissions, or incorrect data.

2. How We Use Your Information

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

• Provide and improve the net worth tracking and related services you request.
• Customize your experience, such as displaying data in your preferred currency or generating tailored charts.
• To facilitate conversational assistance and responses through our AI-powered assistant, which leverages data you have provided, context for which it is provided, preferences and past interactions we have stored, if any, related with your interactions to deliver a more personalized experience.
• To enable us in providing 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.
• Ensure regulatory compliance while transmitting required data to authorized execution partners and intermediaries for completing your financial transactions.
• Resolve disputes, troubleshoot issues, and ensure the Platform's security and integrity.
• Process payments or validate financial data (if applicable).
• Send you updates, reminders, or promotional materials about our services (with an option to opt out).
• Detect, prevent, or investigate errors, fraud, or prohibited activities.
• Enforce our Terms and Conditions and communicate policy changes.
• Respond to your inquiries or comments.
• Analyze usage trends to enhance Platform performance and user experience.
• Contact you for feedback or to offer new features.
• Aggregate the anonymised information from registered users to perform market research, project planning, product development, troubleshoot problems, analyse user behaviour, marketing purposes, and promotions; and
• We use cloud-based software tools to perform certain business-related functions. Examples of such functions include, maintaining databases and servers, processing text messages, phone calls, chats and emails, and marketing and sales analytics. Please note that any Service Partners or Vendors utilised by Pivot.Money by Networth Tracker are bound by the same standards of data security practices and procedures as we are under law and contract.

We may use your IP address and device related information to diagnose technical problems, server issues, administer the Platform, or gather broad demographic data. Optional surveys may collect contact or demographic details to tailor content to your preferences.

Telemetry Information (e.g., anonymized or aggregated data) may be used, stored, processed, or shared for any purpose unless prohibited by applicable law. This includes statistical data or anonymized usage trends that do not identify you.

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 regarding the data we collect and process:

• 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 we hold about you. 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, performance of a task in the public interest, 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 below).

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. This may include cloud storage providers, data analytics services, customer support platforms, and payment processors. These providers are contractually bound by confidentiality and data protection obligations. In some cases, your financial information may be shared to validate accounts or process transactions securely.
• Execution Partners: If you initiate investment or redemption transactions through third-party execution platforms (e.g., BSE, MF Central), we may securely share required identifiers (e.g., PAN, folio number, transaction request details) to facilitate fulfilment of your instructions. These platforms are subject to their own data protection and regulatory frameworks.
• AI Processing Infrastructure: Inputs submitted via NWT GPT may be processed using secure AI infrastructure solely for the purpose of delivering real-time, context-aware responses. No personal identifiers are stored beyond the session unless required to support specific features like goal tracking or historical insights.
• 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. Any such transfer will be 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"). This Policy describes our data handling practices in accordance with the DPDP Act and other relevant data protection laws in India.

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 such as total users to date or total assets tracked, 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 ("Service Partners") other than Pivot.Money by Networth Tracker. The use and operation of any integrated services from our Service Partners such as investment advisory, portfolio management, investing, borrowing, insurance, data aggregation, etc. will be additionally governed by the relevant service terms and contracts of the respective Service Partners. Pivot.Money by Networth Tracker shall not be liable for any penalties, loss or damage which is incurred by you due to the negligence or actions of any Service Partner of Pivot.Money by Networth Tracker and not caused by any action of Pivot.Money by Networth Tracker. The Service Fulfillment Partners are Google analytics, Amazon Web Services(Cloud), Firebase.

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

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 the provisions of 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.
• We employ Encryption of Data at Rest and During Transit
• We use 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, including your login, password, and one-time passwords (OTPs), and for 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 in accordance with applicable regulations.

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.

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.