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Trend Reversal

Privacy Policy

This privacy policy document ("Privacy Policy") is published in accordance with the provisions of Section 43A of the Information Technology Act, 2000 and Rule 4 (1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information.

General

1.

Trend Reversal Analytics Private Limited is a company incorporated under the Companies Act, 2013 (CIN: U66190UP2025PTC224235) ("the Company") with its registered office address Golden-I, Shop No. 442, Block-T3, Plot No. 11, Gautam Buddha Nagar, Gautam Buddha Nagar-201318, Uttar Pradesh that provides a technological solution/platform to facilitate investments in various financial products inter alia includes fixed deposits, Digital gold, Digital Silver, Pre-IPO/Unlisted Shares, Bonds (government bonds and sovereign bonds or Private company bonds) via different partners or vendors on the owned website (www.trendreversal.in) and mobile application of the Company "Trend Reversal Analytics Private Limited" ("Platform"). From time to time, the Platform may allow users to invest in other investment products.

2.

For the purpose of this Privacy Policy, wherever the context so requires, "You" or "Your" or "User" shall mean any natural person who has already signed up on the Platform and intends to access the Platform and/or avail the Offerings on the Platform. Further, wherever the context so requires, "Our", "We", "Us", "Website", "Site", "Trend Reversal" or "the Company" shall mean Trend Reversal Analytics Private Limited, a company registered under the Companies Act, 2013 (CIN: U66190UP2025PTC224235), having the registered office at Golden-I, Shop No. 442, Block-T3, Plot No. 11, Gautam Buddha Nagar, Gautam Buddha Nagar-201318, or its subsidiaries, associates/affiliates.

3.

This Privacy Policy provides specific information on who is processing Your data, how and why it is being processed and Your rights with regard to the control over Your data when availing of the Offerings on the Platform.

4.

Please read the terms of this Privacy Policy carefully before accepting. By accepting the terms of the Privacy Policy, You agree that You have read, understood, acknowledged and accepted this Privacy Policy to access and use the Platform. By directly or indirectly using the Platform, and/or having availed the Offerings on the Platform, in the past, present or future, You explicitly consent to the collection/ sharing/ processing/ use/ storage/ disclosure of Your "Personal Information" and "Non-Personal Information" by Us and our sub-group/ affiliate companies/partner companies/vendor companies with the Company for providing the Offerings on the Platform to You in compliance with this Privacy Policy. We reserve the right to update the terms of the Privacy Policy from time to time. Please ensure that You read the terms of the Privacy Policy periodically to stay updated on the latest version of the Privacy Policy. If You do not accept the terms of the Privacy Policy, the terms and conditions of use ("Terms") and the Disclaimer Document, You must not access or use the Platform.

5.

If You use the Offerings on the Platform on behalf of someone else (such as your child) or an entity (such as your employer), You represent that You are authorised by such individual or entity to (I) Accept the Privacy Policy on such individual's or entity's behalf, and (II) consent on behalf of such individual or entity to our collection/ processing/ use/ storage and disclosure of such individual's or entity's information as described in this Privacy Policy.

Structure of Data Collection & Data Usage

1.

We, the Affiliates and our associate/ affiliate entities/ partner or vendor entities/ may collect/ receive/ share/ process/ use/ store Your information to the extent required to provide the Offerings on the Platform, enhance the user experience, build affluence scores/ user insights, analyse data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations. We may collect/ receive/ share/ process/ use/ store the following information about You as well as the device from which You avail the Offerings on the Platform.

2.

"Personal Information" will inter alia include any information which is directly or indirectly available to Us to identify or verify individual identity. This may also include sensitive personal data which inter alia includes financial information such as bank account, debit card details, and biometric information, KYC (Know Your Customer) details.

3.

"Non-Personal Information" may be collected by Us which cannot be used to identify an individual, while he/she uses the Platform. This information inter alia includes IP address, browser type, and name of the individual's internet service provider or Cookie related data.

4.

Categories of data/ information which We, the Affiliates and our associate/ affiliate entities/ Partner or vendor entities may collect/receive/ share/ process/ use/ store in order to serve You through the Platform:

a.

Personal (Such as Name, address, date of birth, etc)

b.

Contact (Telephone/mobile number(s), email address, residence address, etc)

c.

Financial (Income, Asset details, UPI ID's details, etc)

d.

KYC (Know Your Customer details like proof of identity and address, photograph, Permanent Account Number (PAN), Aadhar or E-Aadhar, signature, email ID, occupational details, etc.)

e.

Transaction details (UPI ID, category and other identifiers along with the details of Offerings on the Platform, mode of payment, location, the date, currency and amount of the transaction, whether the payment was successful, and other information provided by You directly or indirectly to Us or provided to Us by other third party entities. We also store transaction details such as amount spent, transaction ID, date and time of transaction. Further, We may store information relating to Your income, lifestyle levels and usage pattern.)

f.

Use & Tech related data (IP addresses, application, device or browser type, browser language, referring URL versions and configurations, operating systems, device brand and model, time zone setting, geo-location information, content, visitor details collected in our log files, the pages of our Platform that You visit, unique identifiers associated with Your device(s) and pages that You access on the Platform and the dates and times that You visit the Platform, paths taken and other statistics)

g.

Communication details (Communications with customer service support, behavioural data (for example, data collected using cookies), information about promotions, surveys, promotional campaigns and records of Your decision(s) to subscribe or to withdraw from receiving marketing materials, if any.)

h.

Others (Post seeking your necessary permissions we may access Your contact list, SMS, camera, media files and location data in Your devices for various purposes, etc)

5.

You hereby agree, acknowledge and grant Your consent to Us to obtain information/data from You through the Platform, different communication channels, when You provide Your details in forms, surveys, online applications or similar online fields. Further, You hereby agree, acknowledge and grant Your consent to allow Us to obtain/share Your information/data from/to third-party entities including but not limited to our associate/affiliate entities, relevant entities, Registrar and Transfer Agents ("RTAs"), KYC Registration Agency ("KRAs"), business partners/vendors and financial institutions, to the extent required to provide the Offerings on the Platform, enhance the user experience, build affluence scores/ user insights, analyse data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations.

6.

You acknowledge that You are over 18 years of age and are providing Your Personal Information of Your free will.

7.

You acknowledge that We may keep records of communications for making enquiries, orders, feedback or other purposes for rendering services effectively and efficiently. The Company will be the exclusive owner of such data and records. You hereby consent and authorize us to publish feedback obtained from You on the Platform. However, all records are regarded as confidential. Therefore, such records will not be divulged to any third party, unless required by law.

8.

We will store Your Personal Information at least for a reasonable time from the last date of use of the Offerings on the Platform, the Platform or for such period as may be required by law.

9.

We recognise and acknowledge the value and importance of the protection of Your Personal and Non-Personal Information and ensure that the same will be used for the intended purpose(s). By virtue of this Privacy Policy, We will collect/ receive/ share/ process/ use/ store Your Personal Information and/or Non-Personal Information in accordance with applicable laws to provide You with the Offerings on the Platform, enhance the user experience, manage our relationship with You, build affluence scores/ user insights, analyse data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations, etc.

10.

You understand, acknowledge and expressly grant Us Your consent:

a.

To share/ receive Your Personal Information and/or Non-Personal Information with/from Us/ affiliate entities/ business partners, for the purposes which are not limited to providing You with the Offerings on the Platform, improving the existing Offerings on the Platform, enhancing the user experience, building affluence scores/ user insights, outsourcing relationship management activities, analysing data for the introduction of new services and features, and as may be required to comply with any regulatory requirements and contractual obligations.

b.

To share Your Personal Information and Non-Personal Information with the companies that We plan to merge with or entities that We may acquire or be acquired by subject to the provisions of applicable law, in which situation We will require that the new combined entity or the acquired/ acquiring entity follows this Privacy Policy with respect to Your Personal Information.

c.

To collect/ receive/ process/ use/ store certain Personal Information (stated above in 4.a) that You may have shared with the Company or the Affiliates or any other subsidiary company that may be incorporated in the future, in order to allow Us to provide the Offerings on the Platform to You. Further, You expressly consent that certain Personal Information that may be shared by You with Us, including financial information (stated above in 4.c), or Your information that may be collated by Us from the KRAs may be shared with the Company, the Affiliates, the Partners/ Vendors and affiliate entities or any subsidiary company that may be incorporated in the future, in order to facilitate the provision of our Offerings on the Platform to You.

Accessing Third Party Websites or Links

1.

Links to third-party advertisements, third-party websites/ applications/ products/ services or any third-party electronic communication service ("Other Websites") may be provided on the Platform which is operated by third-party entities and is not controlled by, or affiliated to, or associated with Us unless expressly specified on the Platform.

2.

Our Website, mobile site and mobile app may contain links to other websites. Please note that when you click on one of these links, you are entering another website for which We have no responsibility. We encourage you to read the privacy statements of all such sites as their policies may be materially different from this Privacy Policy. Of course, you are solely responsible for maintaining the secrecy of your passwords, and your membership account information. Please be very careful, responsible, and alert with this information, especially whenever you're online.

Information Storing

We may store/retain Your Personal and Non-Personal Information for as long as the same is required for the fulfilment of purposes for which We collected it. The retention of Your Personal Information and/or Non-Personal Information by Us is determined by considering compliance with legal (contractual, statutory or regulatory requirements), accounting and compliance reporting requirements.

Security

1.

The security of Your personal information is important to Us. We take precautions, including administrative, technical and physical measures, to safeguard Your personal information against loss, theft and misuse, as well as against unauthorized access, disclosure, alteration and destruction. When You enter sensitive information on Our registration We encrypt that information.

2.

This Website has various electronic, procedural and physical security measures in place to protect the loss, misuse and alteration of information, or any accidental loss, destruction or damage to data. When You submit Your information via the Website, Your information is protected through Our security systems.

3.

Notwithstanding the above, We are not responsible for the confidentiality, security or distribution of Your Personal Information by third parties outside the scope of our agreement with such third parties. Further, We will not be responsible for any breach of security or for any actions/omissions of any third parties or events that are beyond our reasonable control, including but not limited to, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service or telephone service of the User etc.

4.

No data transmission over the Internet is fully secure, so You acknowledge that We cannot ensure or warrant the security of any information You submit to us. Further, We do not guarantee in any way, the security of any information that You transmit or share on the Platform; and You do so at Your own risk.

Information Disclaimer

We expect you to be responsible for maintaining the accuracy, truthfulness, correctness and completeness of the Personal Information You provide Us, the Affiliates and our associate/affiliate entities/ Partners/ Vendors that is necessary for providing the Offerings on the Platform to You. You shall hold harmless and indemnify Us, the Affiliates and our associate/affiliate companies/ Partners/ Vendors from and against all claims arising out of or in relation to the wrongful Personal Information provided by You to Us, the Affiliates and our associate/ affiliate entities/ Partners/ Vendors

Changes to the Privacy Policy

We reserve the right to change the Privacy Policy at Our sole discretion. We will inform Users of any such change by Us posting the updated Privacy Policy on Our Platform/Website. We encourage You to review this Privacy Policy regularly for any such changes. Your continued use of the Services will be subject to the then-current Privacy Policy.

Contact Details

If You have any questions or concerns with respect to this Terms of Use or the Website or any information contained on thereon, You may contact Us by writing an email to Us at contact@trendreversal.in.

Last updated: 01/08/2025