Privacy Policy

Winvesta India Technologies Pvt. Ltd., CIN U72900MH2019FTC328790 (“Company”, “We”, “Us”, or “Our”), a company incorporated in India with its registered office at 3rd Floor, Birla Centurion, Pandurang Budhkar Marg, Worli, Mumbai, MH 400030 are committed to respecting your privacy and protecting your Personal Information.

We take your privacy very seriously. This privacy policy ("Policy") specifies the manner in which We capture and use the Personal Information that We gather about visitors to this Website and users of Our products and services. Please read the following carefully to understand our views and practices regarding your Personal Information and how We will treat it. It also explains your rights in relation to your Personal Information and how to contact Us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain Personal Information about you. When We do so We are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and We are responsible as ‘controller’ of that Personal Information for the purposes of those laws.

Key terms

It would be helpful to start by explaining some key terms used in this Policy:

Winvesta India Technologies Pvt. Ltd.	3rd Floor, Birla Centurion, Pandurang Budhkar Marg Worli, Mumbai, MH 400030
Special category Personal Information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data Data concerning health, sex life or sexual orientation

Personal Information We collect about you

We may collect and use the following Personal Information about you:

You may provide certain information to Us voluntarily while registering on Our website for availing Our services, such as mobile number, Permanent Account Number (PAN), signature, email address, date of birth, gender, communication and residential address details and proof of address, location, annual revenue, employment type, and source of remittances, corporate bank account details etc. In addition to the Personal Information and in order to provide services to you, We also collect information such as your Aadhaar details etc. as provided in Our KYC policy solely for completing the account opening procedures and authenticating your transactions. The Company hereby agree and acknowledge that they will collect, use, and store such details in compliance with applicable laws and this Policy.

We may also ask you for certain financial information, including details of your Linked bank account, Indian financial system code (IFSC) of the bank, and/or other payment related details or other payment method data, and debit instructions to process the services. We may ask you to provide certain additional information about yourself on a case-to-case basis, either ourselves or via a third party engaged for such purpose by the Company. All information disclosed by you shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity / genuineness / misrepresentation / fraud / negligence of the information disclosed shall lie on the Company nor will the Company be in any way responsible to verify any information obtained from you.

The above information is collectively referred to as ("Personal Information").

This Personal Information is required to provide services to you. If you do not provide Personal Information We ask for, it may delay or prevent us from providing services to you.

What We use your Personal Information for	Our reasons
To provide Services to you	For the performance of Our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you	For our legitimate interests or those of a third party, i.e., to minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use.	For our legitimate interests or those of a third party, i.e., to make sure We are following our own internal procedures so We can deliver the best service to you.
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as We can so We can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to [our financial performance, customer base, product range or other efficiency measures]	For our legitimate interests or those of a third party, i.e., to be as efficient as We can so We can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that We can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g., to make sure We are following our own internal procedures and working efficiently so We can deliver the best service to you.
Marketing our services and those of selected third parties to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom We have had no previous dealings.	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so We can demonstrate We operate at the highest standards To comply with our legal and regulatory obligations

How your Personal Information is collected?

We collect most of this Personal Information directly from you—in person, by telephone, text or email and via Our website and apps. However, We may also collect information:

from publicly accessible sources,
directly from a third party, e.g.,:
- sanctions screening providers;
- credit reference agencies;
- customer due diligence providers;
from a third party with your consent, e.g., your bank
from cookies on our Website—for more information on our use of cookies, please see our cookie policy
via our IT systems, e.g.,:
- automated monitoring of our Websites and other technical systems, such as our computer networks and connections

How and why We use your Personal Information?

Under data protection law, We can only use your Personal Information if We have a proper reason for doing so, e.g.,:

to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.

A legitimate interest is when We have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what We use (process) your Personal Information for and our reasons for doing so:

The above table does not apply to special category Personal Information, which We will only process with your explicit consent.

Promotional communications

We may use your Personal Information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your Personal Information for promotional purposes (see above ‘How and why We use your Personal Information’). This means We do not usually need your consent to send you promotional communications. However, where consent is needed, We will ask for this consent separately and clearly.

We will always treat your Personal Information with the utmost respect and never sell it with other organisations outside the Minden group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

contacting us at support@winvesta.in
using the 'unsubscribe' link in emails or 'STOP' number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We share your Personal Information with?

We routinely share Personal Information with:

companies within the Minden group.
third parties We use to help deliver our services to you, e.g., payment service providers, warehouses and delivery companies;
other third parties We use to help us run our business, e.g., marketing agencies or Website hosts;
third parties approved by you, e.g., social media sites you choose to link your account to or third party payment providers;
credit reference agencies
our insurers and brokers
our banks

We only allow our service providers to handle your Personal Information if We are satisfied they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers relating to ensure they can only use your Personal Information to provide services to us and to you. We may also share Personal Information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some Personal Information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your Personal Information is held?

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who We share your Personal Information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how We safeguard your Personal Information when this occurs, see below: ‘Transferring your Personal Information out of the EEA’.

How long your Personal Information will be kept?

We will keep your Personal Information while you have an account with us or We are providing [products AND/OR services] to you. Thereafter, We will keep your Personal Information for as long as is necessary:

to respond to any questions, complaints or claims made by you or on your behalf;
to show that We treated you fairly;
to keep records required by law.

We will not retain your Personal Information for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of Personal Information.

Transferring your Personal Information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your Personal Information outside the European Economic Area (EEA), e.g.:

with our offices outside the EEA;
with your and our service providers located outside the EEA;
if you are based outside the EEA;
where there is an international dimension to the services We are providing to you.

These transfers are subject to special rules under European and UK data protection law.

If you would like further information, please contact us

Your rights

You have the following rights, which you can exercise free of charge:

Rectification: The right to require us to correct any mistakes in your Personal Information.

To be forgotten: The right to require us to delete your Personal Information—in certain situations.

Restriction of processing: The right to require us to restrict processing of your Personal Information—in certain circumstances, eg if you contest the accuracy of the data.

Data portability: The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

To object: The right to object at any time to your Personal Information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your Personal Information, eg processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

Access: The right to be provided with a copy of your Personal Information (the right of access)

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

email us see below: ‘How to contact us’; and
let us have enough information to identify you
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.

Keeping your Personal Information secure

We have appropriate security measures to prevent Personal Information from being accidentally lost, or used or accessed unlawfully. We limit access to your Personal Information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

If you want detailed information from, Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that We can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this Policy

This privacy notice was published on 16-January-2020 and last updated on 23-January-2023

We may change this privacy notice from time to time—when We do We will inform you via our website

How to contact us

Please contact us by email or telephone if you have any questions about this Policy or the information We hold about you.

Our contact details are support@winvesta.in