Last updated: October 19, 2022

We at Noble Wealth Technologies (“we”, or “us”) know you care about how your personal information is used and shared, and we take your privacy seriously. This Statement explains our policies and practices and applies to information collection and use including but not limited to while you are using Mira Money (the Platform). Please read the following to learn more about our Privacy Policy. By using or accessing the Services on the Platform in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of the Platform is at all times subject to the Terms of Use, which incorporates this Privacy Policy.  Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

What does this Privacy Policy cover?---------------------------------

This Privacy Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage.

• What information do we collect
• …… and Why
• Will We Share Your Information?
• Link to other sites
• Will we ever change this Privacy Policy?
• Transfer of Data
• Is Personal Information about me secure?
• What Personal Information can I access?
• What choices do I have?
• Questions about this Policy

What information do we collect?------------------------------

We gather various types of Personal Information from our users, which includes information you provide us, information collected automatically, and information collected from other parties.

Information You Provide to Us:

We receive and store any information you knowingly provide to us.  For example, through the registration process and/or through your account settings on the Platform, we may collect, without limitation, Personal Information such as

1. Full name as its in Aadhar card/PAN card
2. Mobile Number
3. Place of birth
4. Aadhar details
5. PAN details
6. Bank account details
7. email address
8. Phone number
9. Nominee name, DOB, Place of birth and % of benefits for each nominee
10. Occupation details
11. Source of income
12. Cancelled cheque photo

We may communicate with you on the email provided during creating the account on the Platform. For example, we email you regarding your investments and transactions.

Promotional and other emails are also sent to your email id. If you do not want to receive these specific communications from us, you have the opportunity to unsubscribing from the same on the Platform itself.

Information collected through Cookies:

“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your device and tell us how and when the Platform and its Services are visited and by how many people.  You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.  Also, if you click on a link to a third-party website or service, such third party may also transmit cookies to you.  Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honour “Do Not Track” requests you have set using your browser or device.

In certain cases, we may also share some Personal Information with third parties, but only as described below.

… and Why?----------

We use this Personal Information internally in connection with our Services, including:

1. Customers profile data will be used to personalize the offerings and personalize the message in the app
2. We use customer profile data for our internal analysis purposes only to understand the investment pattern behaviour like money invested by age group, etc so that we can improve our services further using these insights. No data is shared or sold with any vendor or partner outside of Noble Wealth Technologies for commercial purposes

Will We Share Your Information?-----------------------------

We may share your Personal Information with following for smooth delivery of our product:

1. Fintech Primitives platform by Cybrilla Technologies for facilitating discovery of mutual funds, purchase and redemption of funds, payment to mutual fund houses (AMCs). Hence, required customer data will be sent as part of communicating with these external platforms in an encrypted manner with all safety and security in place.
2. Pulse Labs Research & Technology Solutions Pvt Ltd - Though our platform interacts with this platform to get mutual funds related data, we do not share any customer specific data here.
3. CAMS (Computer Age Management Systems) - We share customers profile data with CAMS in order to provide investment related views to our customers. CAMS is a SEBI-registered RTA (Registrar & Transfer Agents). CAMS helps mutual fund companies with record maintenance and give investors single-window access to all their investment related information.
4. KFintech - We share customer profile data with KFintech in order to provide investment related views to our customers. KFintech is a SEBI-registered RTA (Registrar & Transfer Agents). KFintech helps mutual fund companies with record maintenance and give investors single-window access to all their investment related information.
5. Asset Management Company (AMC) - We share customer profile data with AMCs. AMCs are the mutual fund houses who create and sell investment products like mutual funds, PMS, etc. To facilitate the buying and selling of mutual funds, we do share customer data with AMCs in a secure manner.
6. RazorPay - RazorPay is our payment gateway for the money transfer between customer bank account and AMCs. In order to facilitate the transaction, we share customer profile data, bank account details, amount to be transferred, etc with RazorPay to facilitate the transfer of funds.

Business Transfers:

 We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Protection of Noble Wealth Technologies and Others:

We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Noble Wealth Technologies, our employees, our users, or others.

Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities

Will we ever change this Privacy Policy?------------------------------------

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing the new Privacy Policy on the Platform. We will let you know via email and/or a prominent notice on the Platform, prior to the change becoming effective and update "effective date" at the top of this Privacy Policy. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them.  If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

Transfer of Data---------------

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Is Personal Information about me secure?--------------------------------------

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavour to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security.  Unauthorized entry or use, failure of the Services, or other factors may compromise the security of user information.

We use following processes for storage of user information:

1. During transmission of user data between app and our backend servers, we use API level security and encrypt all sensitive data in the REST requests using AES Encryption and encryption keys will be managed using Amazon AWS’s KWS (Key Management Service)
2. Access to stored data: We use separate logins to different access as part of our identity and Access management. For example, admins and devops are separate logins.
3. Network isolation for our servers & stored data: Using Amazon VPC (Virtual Private Cloud), we have restricted access to data & database only for our services running inside these VPCs.
4. Application layer level threat prevention: We secure our APIs by using token authentication mechanism and CORS policy to prevent attack via frontend APIs.
5. We use HTTP Post method for transmitting for transmitting authentication credentials & SSL security is enabled on pages wherever required to mitigate server spoofing and phishing
6. Passwords are stored using salted cryptographic hash
7. Session tokens are generated using strong and non-predictable algorithms.
8. We ensure that all session tokens expire automatically at a predefined period of inactivity, currently configured for 24 hours

What Personal Information can I access?-------------------------------------

Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:

• name and password
• email address

The information you can view, update, and delete may change as the Services change.  If you have any questions about viewing or updating information we have on file about you, please contact us at support@mira.money.

What choices do I have?----------------------

You can always opt not to disclose information to us, but keep in mind some information may be needed to register on the Platform.

You may be able to add or update information as explained above.  When you update information, however, we may maintain a copy of the unrevised information in our records. We maintain historical data for auditing purposes. We may use any aggregated data derived from or incorporating your Personal Information after you update or disable, but not in a manner that would identify you personally.

What if I have questions about this policy?--------------------------------------

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to support@mira.moneyand we will try to resolve your concerns.