Privacy Policy

Privacy Policy

SJAM Fin Services Private Limited (hereinafter referred to as “TopMoney/ we/ our”) acknowledges the expectations of its customers (hereinafter referred to as “customer/ you/ your”) regarding privacy, confidentiality and security of personal information that resides with the TopMoney. Keepersonal informationng personal information of customers secure and preventing any misuse thereof, is therefore, a top priority of TopMoney.

We affirm that TopMoney is strongly committed to protect the privacy of its customers and has taken all necessary and reasonable measures in line with the best industry practice to protect the confidentiality of your personal information and its transmission through our website.

Privacy & Security policy (hereinafter referred to as “Policy”)therefore, explains how we protect your personal information provided to us on our website i.e. www.topmoney.in and how we use that information in connection with the service offered through the Website and must be read in combination with our General Terms of Use.

Personal Information

Personal Information means any information/ documents/ details that relates to a natural person, which either directly or indirectly in combination with other information available with TopMoney, can identify such person.

Mutual Funds

(a) TopMoney collects, receives, possesses, stores, deals or handles personal information received from investors/client/customers whether existing or prospective. Such personal information may be as per the list given below:

1. Bank Account details, change of bank account details or registration of multiple bank accounts etc. through application forms;
2. Payment instrument details at the time of submitting application at the time of investment or as proof for carrying out change of bank account or any other details of debit card obtained (if any);
3. Generation and storing password (personal information) in encrypted form based on the request from the investor under the online mode of investments;
4. Demographic /Biometric information obtained, if any;
5. Demat Account details like beneficiary account no. etc.;
6. Annual Income and savings profile; and
7. Any other information as may be considered as personal information.

(b)The aforesaid information is being collected by TopMoney to respond to your requests, to process the investment applications and to also ensure safe subscriptions/redemptions of mutual fund investments. TopMoney may also call you to inform them with respect to the other products or services offered by its partner AMCs. The said information is also being collected to be compliant with the Know Your Client (KYC) norms under the Prevention of Money Laundering Act, 2002 (PMLA), the rules issued thereunder, and guidelines and circular on Anti- Money Laundering issued by SEBI and SEBI (Mutual Funds) Regulations, 1996 as amended till date.

Unsubscribe

In case you do not want to be disturbed over telephonic calls, kindly fill up the details requested in the below table, including the details of the telephone number(s) on which you do not wish to be contacted and submit the same at unsubscribe@topmoney.in from your email address registered at TopMoney. The details that you provide through the unsubscribe email will remain confidential and once you have submitted the same to us, your telephone number(s) will be removed from all our telemarketing calling lists within 10 working days. We will make every effort to ensure that you do not get any further telemarketing calls on such telephone number(s).

Function and Practice

a) TopMoney will not sell or rent your personal information to anyone, for any reason, at any time. However, we will be sharing your personal information with our affiliates, where we feel that you will be assisted better for the purpose of underwriting and approval of your credit card, loan or any other financial product transaction/related transaction; or for doing a check of your credit profile on your behalf and sending you targeted communications and offers. We assure that TopMoney will always seek your consent to process certain types of information where it is legally required to do so. TopMoney uses the personal information collected to manage its business and offer you an enhanced, personalized online experience on its Website. By registering on the Website, you authorize TopMoney to send SMS and e-mail alerts to you for its service requirements, including sending promotional e-mails and SMSs. Further, it enables TopMoney to: send you any administrative notices, offer alerts and other communications relevant to your use of the Service, display tailored product offers to you and enable you to apply for certain products and services for which you have chosen to apply, carry market research, project planning, troubleshooting issues, detecting and protecting against error, fraud or other criminal activity, improve our Services and manage our customer relationships better, enforce TopMoney General Terms of Use,comply with all applicable laws and regulations.
(b) In the event that you access the Service as brought to you by one of our partners either through the Website or on being redirected from a co-branded URL or any other website , your name, e-mail address, mobile number, date of birth, employment type, residency status, income details/proofs, Form 26 AS, PAN, details of loan / credit card/ mutual fund applied for and loan, credit card and mutual fund status or any other financial product status may be provided to that partner when your application is submitted and whenever the status of application is updated. TopMoney has a business relationship with these partners and you may not opt-out of sharing your information with these partners if you have applied via a co-branded URL or any other website or directly through the Website as the case may be.
(c) For availing the Service such as applying for credit information report, loan, credit card, mutual fund or any other financial product we will require you to provide/upload on the Website the details such as a your name, parentage, marital status, email address, nationality, location, mobile number, PAN, employment & income details/proofs, Form 26 AS, recent photograph, signature image, other Know Your Customer (KYC) documents like address proof, identity proof and personally identifying information about a potential co-loan applicant (should you select this option), and to participate on our forum boards, you must provide a username for yourself.
(d) You may unsubscribe of location-based services at any time by editing the setting of your browser.
(e) In order to provide your bank statement or pay slip electronically along with your loan application, you also must provide your third-party account credentials ("Account Credentials") to allow TopMoney to retrieve your account data at those other financial institutions ("Account Information") for your use. Your Account Credentials are only used once to retrieve your bank statements/pay slips, Form 26 AS and are not stored in our system. TopMoney shall not be liable to you against any liability or claims which may arise out of such transactions being carried on your own accord.
(f) We may also use third party service providers to provide the Service to you, such as sending e-mail messages on our behalf or hosting and operating a feature or functionality of the Service. Our contracts with these third parties outline the appropriate use and handling of your information and prohibit them from using any of your personal information for purposes unrelated to the product or service they're providing. We require such third parties to maintain the confidentiality of the information provide to them.

Disclosure / Sharing

(a) TopMoney does not disclose personal information of a customer except as directed by law or as per mandate received from the customer / applicant. Upon your written request TopMoney will provide you with information on whether we hold any of your personal information. No specific information about customer accounts or other personally identifiable data is shared with third parties unless any one of the following conditions is met:
1. To help complete a transaction initiated by you;
2. To perform support services through a third-party service provider, provided it conforms to the Privacy Policy of the TopMoney and your prior consent to do so is obtained;
3. You have specifically authorized it;
4. Where the disclosure is necessary for compliance of a legal obligation or as required by law, such as to comply with a subpoena, or similar legal process;
5. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
6. There are number of products/services such as loans, credit cards, mutual funds, offered by third Parties on the Website, such as lenders, banks, credit card issuers. If you choose to apply for these separate products or services, disclose information to these providers, then their use of your information is governed by their privacy policies. TopMoney is not responsible for their privacy policies. TopMoney may share your data with other third parties, such as service providers, advertisers, Credit Information Companies, fraud prevention agencies, marketing channels, affiliates, without the need for additional consent from you.
7. TopMoney shall not be held liable for disclosure of the personal information when used in accordance with this Privacy Policy or in terms of the ‘General Terms of Use’ of Website or an agreement, if any, with the users of Website .

MODIFICATION IN PERSONAL INFORMATION

(a) If your personal information provided to us when you had applied for a product on our Website changes, you may update it whenever you apply for a new product via our Website. To review and update your personal information and to ensure that the same is accurate while your application is in process, you may contact us at support@topmoney.in. You will not be able to update the information you have provided in an application after a decision has already been made on it; however, you may create and submit a new application with your updated information.
(b) Note: We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at support@topmoney.in. We will respond to your request within a reasonable timeframe. However, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.

MAINTENANCE OF YOUR DATA

(a) TopMoney will maintain your information for as long as it is necessary for providing you the Services available on the Website or your request for termination of your account with TopMoney, whichever is later.
(b) Post termination of your account, TopMoney may continue to use your unspecified data aggregated or in combination with unspecified data of other users. We use this aggregated unspecified data for data analysis, profiling and research purposes, for example to gain insights about our users and their profiles. We may keep your contact information along with your application details (if any) for fraud prevention purposes and for the exercise/ defense of a legal claim or for providing evidence in legal proceeding(s).

EMAIL & SMS COMMUNICATIONS

We provide our registered customers with periodic email/SMS alerts. We also allow users to subscribe to email newsletters and from time to time may transmit emails promoting TopMoney or third-party products. Subject to the express consent clause above, TopMoney Website subscribers may opt-out of receiving our promotional emails and terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related e-mails/SMS, such as e-mail/SMS alerts. The above services are also provided by our partners.

RECORDED FILES

This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or click stream data. We may use the collected log information about you to improve services offered to you, to improve marketing, analytics, or Website functionality.

TRACKING TECHNOLOGIES

TopMoney and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

THIRD PARTIES WILL NOT BE GIVEN YOUR PERSONAL INFORMATION UNLESS YOU GIVE CONSENT TO TOPMONEY

There are several products and services, such as credit information report, loans, credit cards, mutual fund and other financial products being offered by third parties on our Website, such as lenders, banks, credit card issuers and mutual funds (collectively "Offers"). If you choose to apply for these separate products or services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies. You should evaluate the practices of these external services providers before deciding to use their services. TopMoney is not responsible for their privacy practices.

WE KEEP YOUR DATA SECURE

(a) We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. Since no method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, we cannot guarantee its absolute security. If you have any questions about security on our Website, you can contact us at privacy@topmoney.in.
(b) We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect TopMoney online accounts and systems from unauthorized access.
(c) When you register for the Service, TopMoney requires a password from you for your privacy and security. TopMoney transmits information such as your login credentials for Website or Account Credentials securely.
(d) Our servers are in secure facilities where access requires multiple levels of authentication, including an identity card and biometrics recognition procedures. Security personnel monitor the facilities round the clock 365 days a year.
(e) Our databases are protected from general employee access both physically and logically. We encrypt your Service password so that your password cannot be recovered, even by us. All backup drives and tapes also are encrypted.
(f) We enforce physical access controls to our buildings. No employee can put personal information on any insecure machine (i.e., nothing can be taken from the database and put on an insecure laptop). We permit only authorized employees who are trained in the proper handling of customer information, to have access to aforesaid personal information.
(g) TopMoney has been verified for its use of SSL encryption technologies.

YOU ARE RESPONSIBLE FOR MAINTAINING THE CONFIDENTIALITY OF YOUR LOGIN ID AND PASSWORD

(You are responsible for maintaining the security of your login ID and Password and must not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at privacy@topmoney.in. We are not responsible if someone else accesses your account through the login credential they have obtained from you or through a violation by you of this Privacy and Security Policy or the TopMoney Terms of Use. If you have any security related concern, please contact us at privacy@topmoney.in. We will work closely with you to ensure your personal information and personal response to your concerns.

ISO 27001

ISO/IEC 27001:2013 is the international standard for management of information security and provides a systematic approach to keep your personal information and sensitive company information secure. Getting the ISO 27001:2013 certificate is a reassurance for our customers that TopMoney complies with the highest standards regarding information security. TopMoney is ISO/IEC 27001:2013 certified under certificate number IND17.0322/U. We have implemented the ISO/IEC 27001: 2013 standard for all processes supporting the development and delivery of services by Top Money.

CONTACT US WITH ANY QUESTIONS OR CONCERNS (GRIEVANCE REDRESSAL)

If you have grievance or complaint, questions, comments, concerns or feedback in relation to the processing of information or regarding this Privacy and Security Policy or any other privacy or security concern, send an e-mail to privacy@topmoney.in.

CHANGES IN THE PRIVACY POLICY

We may amend this Privacy Policy from time to time. It is our policy to post on the Web Site all the changes made in the Privacy Policy and Terms of Use of the Web Site and we request you to keep yourself updated accordingly.

EFFECTIVE DATE

June 1, 2019