Privacy policy

Effective Date: January 3, 2019

Hi and welcome! You are reading Base’s privacy policy. We recommend that you read this privacy policy carefully before you use our site, our services or products. We've tried to keep it clear and straightforward. If you have any suggestions, do not hesitate to email us at hello@baseaccount.com

To make the terms more readable, we’ve included annotations throughout the contracts. These annotations aren't a part of the policy itself, but are intended to help you follow the text and break the terms down to their essence. In order to gather a complete understanding of the terms of this Policy, please read the entire contents of the same.

The Company recognises the importance of maintaining the privacy of the information belonging to you. This Policy sets out details of how we treat user information we collect on baseaccount.com (the "Website" and its subdomains).

"We are Shadegrown Tech and you are agreeing to these terms."

The Website is owned and operated by Shadegrown Tech Private Limited, a private limited company registered under the provisions of the [Indian] Companies Act 2013 having its registered office at Flat Number 305, Fortune Residency, Doddanagamangala Main Road, Electronic City Phase II, Bangalore, 560 100, Karnataka, India (the “Company”).

By visiting and/or using the Website, you agree to the terms of this Privacy Policy and it shall be deemed that you have read in full, accepted and agreed to the terms herein.

"We may change this privacy policy. If we make any significant changes, we'll tell you."

The Company reserves the right to modify the terms contained in this Privacy Policy at any time by notifying each User regarding such change. However, changes that are minor in nature (for example, we may make changes to passive collection tools we use, say we replace Google Analytics with something else) may not be specifically notified to Users. The modified Privacy Policy woud be effective from the date of modification that is posted by the Company on the Website after the communication regarding the same is sent. If you do not agree to any term that is contained in this Privacy Policy, please immediately cease your use of the Website.

"We're in India, and follow the Indian law. But we really like EU’s data protection laws, so we’ve tried to to make our privacy policy as closely compliant with the GDPR as possible."

This Privacy Policy is issued pursuant to the provisions that are contained in (a) Section 43A of the Information Technology Act, 2000; (b) Reguation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rues, 2011; and (c) Reguation 3(1) of the Information Technology (Intermediaries Guidelines) Rues, 2011. This Privacy Policy is also intended to be compliant with the requirements set out in the General Data Protection Reguations issued by the European Union (the "GDPR") to the extent possible.

"Whatever information we collect from you will be only used to provide Base services to you. We’ll never sell or rent it to any third party."

Information that is collected by the Company on the Website shall be used by the Company only for the purpose of providing the Services, and such information shall not be used, sold, transferred or rented in a manner that is not set out in this Privacy Policy.

Information that is collected by the Company:

Information About User: "To provide our services to you, we may collect personal information about you."

In providing the various services that are available on the Website (the “Services”), the Company may have to collect certain personal information from you. This information would, inter alia, include the following:

Contact information: the Company may collect your name, email id, mobile number, postal address etc.

"We may use third party services which may use your data to provide additional services. But we will do it only after receiving your explicit permission to use them."

Information to provide the Services: the Company shall use the data provided by you to share the same with external third party platforms with your explicit consent in order to provide the Services. The Company shall collect your Unified Payment Interface (UPI) ID at the time of registration on the Website. The Company may, in the future, seek access to your banking transactions either by requesting you to forward your transaction confirmation emails or SMS' to the Company, or by obtaining a direct authorisation from your bank. Such information woud be applied by the Company only to provide the Services. The Company may also use the information submitted by you to give you various options and methods to plan and manage your finances.

"When you use Base to purchase Mutual Funds, you will be required to give us additional information about yourself for us to facilitate the transaction."

Where you are availing of the facilitation services provided by the Company for investments into mutual funds, you will be required to provide the following additional information to the Company:

PAN number
Mobile number
Email
Date of birth
Current residential address
Bank account type
Bank account IFSC code
Bank account number
Occupation
Income Range
Information on the Tax Residency status
Confirmation on whether the User is a ‘Politically Exposed Person’ (defined by the Financial Action Task Force and the Securities and Exchange Board of India as an individual who has been assigned a prominent public function and includes ministers of State, Parliament members, officers of the judiciary, members of local statutory governing bodies etc.)
Confirmation on whether the User is related to a ‘Politically Exposed Person’
Confirmation on whether the User pays taxes in India
Confirmation on whether the User was born in India

"Normally, when you visit Base we receive your IP address and information about your browser."

Other information. While you use the Website, the Company may collect information about your IP address and the browser you are using.

"We will never up-sell any financial products or services without your permission"

The Company shall not use the data provided by a User for up-selling any financial product without an explicit permission from such User.

"We will not combine your data with third party brokers without your permission. We will also send you a periodic/monthly reminder about your consents provided to external service providers"

The Company will not profile the User by associating the data submitted by him/her with third party data brokers without explicit consent of the User. The Company shall also send every User periodic/monthly reminders of consents provided by such User.

"You are providing your data voluntarily to us and we're keeping your data reasonably safe"

You acknowledge and agree that any and all information that is provided by you on the Website is provided by you voluntarily and at your own risk. While the Company woud make all efforts to ensure the safety and security of the information provided for you, the Company cannot guarantee against a potential security breach.

"Even after you delete your account, some information may persist for a while."

Please note that any information that is provided by you may be retained by the Company for (i) providing the Services; and (ii) for meeting its obligations under applicable law.

"You are responsible for the data you provide and can withdraw your consent, delete your account or request an erasure of your data at any point of time."

You shall be responsible for the accuracy of the information provided to the Company for the use of the Website and the Services. If there is any mistake in or change to the personal information provided by you for the use of Website, you shall immediately notify the Company at [legal@shadegrowntech.com]. You shall be solely liable for the consequences of providing incomplete, inaccurate or incorrect information on the Website. Where the Company has reasons to believe that the information provided by you on the Website in incorrect or incomplete, the Company may restrict you from using the Website by disabling your User Account.

If you want to discontinue the use of the Website, or if you want to withdraw the consent granted to the Website for collecting and processing your data, please notify the Company at [legal@shadegrowntech.com]. Once you discontinue the use of the Website or withdraw your consent, the Company shall retain the personal information provided by you on the Website for such time period as may be mandated by applicable law and thereafter erase the same in full. Such erasure shall be notified to you by way of an email.

Information may be collected in several ways:

"Active collection is when you directly give us information through forms, email, etc"

Active collection: This refers to the information that is actively provided by you while registering on the Website, while browsing and/or purchasing products on the Website, while making payments using the payment gateway on the Website etc.

"Passive collection refers to information we may deduce about you through your interests and behaviour from your activity. We only do that to provide Base services to you."

Passive Collection: This refers to the information that is gathered by the Company using tracking tools like Google Analytics, Google Webmaster, browser cookies etc. for collecting information about your usage of our Website, email, app and notifications. This information may be used by the Company for internal research to understand User demographics, interests and behaviour with a view to improving the functionality of the Website. This information may include the URL of the website that you visited just before visiting the Website or which one you go to after visiting the Website, your computer browser information, and your IP address.

While the Company does not actively collect any information from persons who visit the Website, but do not register themselves on it or avail of the Services, certain portions of this Privacy Policy woud be applicable to such visitors as well.

Use of Information About User: "We may use your personal information for a variety of reasons such as communicating changes, addition of new features and improving our security."

Use of your personal information by the Company:

To contact you: The contact information you provide woud be used by the Company to contact you in relation to the provision of the Services.

To improve the quality of the Services. The Company might use your information to improve the functionality of the Services and to ensure that its quality is maintained / bettered.

For security purposes. The Company might use the information provided by you on the Website to protect our company, our customers, or our websites.

For marketing purposes. The Company might send you information about special promotions or offers. The Company might also notify you of new or improved features on the Website.

Transactional communications. The Company may also contact you by way of emails or SMSs to keep you informed of the various actions taken by the Company in the course of providing the Services.

The Company shall use your information only in a manner that is permitted by applicable law.

Processing of the data collected by the Website

Information Related To How Your Data Is Processed: "We use third party platforms that you have consented to process your data in order to provide services requested by you."

All the data provided by a User woud be processed by the Company since such data woud have to be stored and thereafter applied for servicing transaction requests raised by a User from time to time.

The purpose of the processing is to facilitate the requests by the User either directly from the Website or through the applets on the Third Party Platform or any other third party who has access to our APIs, that the User has consented to share their data with. It would also be used to improve the functionality of the Website by understanding financial patterns after removing any personally identifiable information from the data.

Information Related to Use of the Services: "We use third party statistics and analytics services."

The Company woud be using external service providers like Google Analytics, Consently.co, Intercom etc. for both fixing site performance issues and to provide customer support to our Users. We may also look for appropriate tools for this in the future.

Information We Share with Your Consent or at Your Request: "We won’t be publishing your processed data. But If you want us to provide you or share it with someone else, we'll do it."

The Company woud not be publishing the processed data unless the processing is pursuant the Users’ request in which case it will be either provided to the User on the Website/email id or provided to any third party they have consented to share the data with.

Consent provided by user: "If you object to any consent provided by you, you are free to remove it."

Where a User wants to object / withdraw the consent that has been provided by her / him for processing the data, the User may visit the Website and remove the consent provided for data processing on the Website in the manner set out on the Website.

Sharing of information by the Company with third-parties:

Information Shared with Third Parties: "We may share your personal data with other service providers for things like to processing payments or sending messages."

Service Providers. Besides IFTTT Inc., the Company shall share your information with other persons who the Company has contracted with for assistance with performing the Services such as payment processors or transactional message processors. The Company may also avail third party service providers like Amazon Web Services, Cloudflare, Gandi.net, Google Cloud Platform, Mailchimp, Razorpay, Sendgrid where the Company hosts its domain name, infrastructure, databases and the Website.

Information Disclosed for Our Protection and the Protection of Others: "We will disclose information if needed to obey the law."

Compliance with law. The Company might share your information to respond to a court order or subpoena. The Company may share your information if a government agency or investigatory body requests the Company to do so.

What happens to your data in the event of a Merger or Acquisition: "If we sell Base or its assets, your information woud be transferred to the new owners."

Mergers and Acquisitions. If the Company sells its business or hives of a portion of the same to a new entity, your personal information that is available on the Website may be transferred to the new entity.

SECURITY OF YOUR INFORMATION

"We're keeping your data reasonably safe.

Please note that neither the Company nor any of its employees woud have access to the password that relates to your User account on the Website. You shall be solely responsible for protecting your login credentials to the Website, and the Company shall not be liable in any manner for unauthorised use of your login credentials. You shall be liable to the Company for any loss suffered by the Company as a result of unauthorised use of your login credentials. In the event of any misuse or suspected misuse of the same, please notify the Company at legal@shadegrowntech.com.

While the Company shall seek to implement the best market practices and security policies for the protection of your personal information, it shall not be liable for improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. It is expressly stated that the Company shall not be responsible for any breach of security or for any actions of any third parties that receive Users' personal data or events that are beyond the reasonable control of the Company including, acts of government, computer hacking, unauthorized access to computer data and storage devices and storage technology, hardware, computer crashes, breach of security and encryption etc.

Information Collected Using Cookies: "When you grant us the permission, the information collected through cookies is used only to improve our services. We do not control the use of cookies by third parties."

Cookies: A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you grant the permission, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particuar site. The Company uses traffic log cookies to identify which pages are being used. This helps the Company analyze data about web page traffic and improve the functioning of the Website. This information is used by the Company only for statistical analysis and then the data is removed from the system. Please note that the Company does not have any control over the cookies that are placed by third party links on the Website. The Company does not represent to you that such third party websites have their own privacy policies or that the information that is provided by you to them woud be secure.

THIRD PARTY SITES

"This Policy covers information you share with Shadegrown Tech, not third parties. We highly recommend that read their privacy policies."

As stated in the Terms of Use available at ToS, any data that is shared with https://ifttt.com/ is shared with your prior explicit consent. Please note that the Privacy Policy issued by IFTTT Inc. and published at https://ifttt.com/privacy would be applicable to such information. Once the data shared by you with the Company is shared with IFTTT Inc., the Company shall have no control over the same, and the Company disclaims all liability with respect to the use, storage and application of such data by IFTTT Inc.

If you click on one of the links to other third party websites that may be available on the Website, you may be taken to websites that the Company does not control. This Privacy Policy does not apply to the privacy practices of those websites.

The Company shall not be liable for the misuse of your personal information by third party websites.

REDRESSAL OF GRIEVANCES

"If you have any questions or complaints about Base, email us. We will get back to you within a month."

If a User has any questions or grievances regarding the Website, the contents thereof, the manner in which personal data is being collated or processed by the Website or regarding the Services, the User may reach out to Praneeth Bodduluri of the Company customer support at legal@shadegrowntech.com (the “Grievance Officer”). The Grievance Officer shall address any complaint or grievance that is raised by a User within a period of one (1) month from when it is raised.

Where the Company requires additional information to process and respond to the query raised by a User, the Company shall notify the User of the same.

MISCELLANEOUS PROVISIONS

"If we are affected by a major event like an earthquake, we may have to suspend our operations."

Force Majeure. The Company shall not be responsible for any cessation, interruption or delay in the performance of its obligations hereunder due to earthquake, flood, fire, storm, natural disaster, act of God, war, terrorism, armed conflict, labor strike, lockout, or boycott. The Company may at any time, in its sole discretion and without advance notice to you, cease operation of the Website and the provision of the Services.

"A delay or failure in exercising any of the terms mentioned here doesn’t imply that we’re giving up on them."

No Waiver. A delay or failure by the Company to exercise or enforce any right or provision of this Privacy Policy will not constitute a waiver of such right or provision.

"We will email or mail you our notices in English. You can mail us your notice to our registered address."

Notices: All notices given to a User by the Company or by a User to the Company or another User shall be in writing and in the English language. Such notice shall be sent by e-mail or mailed by a prepaid internationally-recognized courier service to the intended recipient at the address set out below, or any changed address that is notified by either Party:

Notice to the Company:

Shadegrown Tech Private Limited
Flat Number 305, Fortune Residency,
Doddanagamangala Main Road, Electronic City
Phase II, Bangalore, 560 100, Karnataka, India
Email: legal@baseaccount.com

Notice to User:

At the email address provided by you at the time of registration on the Website.

"This agreement is covered by Karnataka law. If there is a dispute between us, we'll handle it in Karnataka"

Governing Law; Jurisdiction. This Privacy Policy is governed by the provisions of Indian law, including but not limited to the following:

the Indian Contract Act, 1872;
the (Indian) Information Technology Act, 2000;
the (Indian) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011; and the (Indian) Information Technology (Intermediaries Guidelines) Rules, 2011.
This Website originates from the State of Karnataka in India. This Privacy Policy will be governed by the laws that are applicable in the State of Karnataka. By using this Website, you consent to the jurisdiction and venue of the courts located in Karnataka, India in connection with any action, suit, proceeding or claim arising under or by reason of this Privacy Policy.

This Website originates from the State of Karnataka in India. This Privacy Policy will be governed by the laws that are applicable in the State of Karnataka. By using this Website, you consent to the jurisdiction and venue of the courts located in Karnataka, India in connection with any action, suit, proceeding or claim arising under or by reason of this Privacy Policy.