This document is an electronic record in terms of Information Technology Act, 2000 and rules made thereunder as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures. This privacy policy document (“Privacy Policy”) is published in accordance with the provisions of 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.

The privacy policy (“Stable Money Bonds Privacy Policy” or “Policy”) explains how Stable Broking Private Limited (“our”, “us”, “we”, Company”), and other group companies (i.e. Stable Alpha Technologies Private Limited and Stable Finserv Private Limited) collect, store, use, transfer and otherwise process your personal data, in connection with or related to providing you the Stable Money Bonds Services (defined in the Stable Money Bonds Terms of Use) through the Stable Money Bonds website (“Website”) or through the Stable Money Bonds mobile application (“Mobile App”). We may revise this Policy as well as update the Stable Money Bonds Services, from time to time, so please keep visiting this page regularly to take notice of any changes we make. If you do not agree with any part of this Policy, please stop using our Stable Money Bonds Services immediately. Further, if at any time, you wish to manage your consent for processing of your personal data, please reach out to us through the ‘Contact Us’ on the Website or the Mobile App, or by e-mail to our grievance redressal officer. This Policy, incorporates, and includes the Stable Money Bonds Terms of Use, available here (“Terms”) and the agreement(s) executed by you (and members, nominees, if any) for availing the Stable Money Bonds Services.

The capitalized terms that are used but not defined in this Privacy Policy will have the same meaning as in our Terms and Conditions. By using the services or by otherwise giving us your information, you will be deemed to have read, understood and agreed to the practices and policies outlined in this privacy policy and agree to be bound by the privacy policy. You hereby consent to our collection, use and sharing, disclosure of your information as described in this privacy policy.

Words and phrases not defined in this Policy shall have the same meaning as set out in the Terms.

You acknowledge that this Privacy Policy is a part of the Terms, by accessing the Mobile App or the Website or by otherwise providing Us with your Personal Information or by making use of the services provided by the Mobile App or the Website, You signify Your (i) assent to the Privacy Policy, and (ii) consent to the Utilisation of your Personal Information in accordance with the provisions of this Privacy Policy, by checking the check box presented with this Policy.

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

You have the option not to provide us the Personal Information sought to be collected. You will also have an option to withdraw your consent at any point. We strive to address your concerns and provide necessary assistance throughout the process. However, please be informed that deleting your data, withdrawing certain mandatory permissions, or revoking the consent to process and store information such as your Stable Money Bonds Account Data, KYC Information, and/or your basic personal information needed to facilitate your investment in the bonds offered as part of Stable Money Bonds services may affect the functionality and availability of services availed by you on the Website. We may have to cease the provision of, your access to or use of the Stable Money Bonds Services or the Website to facilitate your request for deletion of your data, or revocation of mandatory permissions or consents. We will make every effort to inform you of the data attributes that are necessary to be retained by us under applicable laws or for our fraud detection and prevention, reporting purposes or dispute management.

Please note that our processes for facilitating your requests for deletion of data, or withdrawal of consent are governed by our internal policy on data deletion, data retention, and consent revocation. For any further assistance, please write to us at [email protected].

If you have any queries, concerns, or grievances regarding this Policy, or the processing of your information, you may please write to our grievance redressal officer, Pranav Iyer at:[email protected].

We request you to please provide the following information in your complaint:-

1. Identification of the information provided by you.
2. Clear statement as to whether the information is personal information or sensitive personal information.
3. Your address, registered telephone number or e-mail address.
4. d. A statement that you have a good-faith belief that use of the information has been processed incorrectly or disclosed without authorization, as the case may be.

We may reach out to you to confirm or discuss certain details about your complaint and issues raised. We shall not be responsible for any communication, if addressed, to any non-designated person in this regard.

In order to provide services to you we might require you to voluntarily provide us certain information that personally identifies you. You hereby consent to the collection of such information by Us. The information that we may collect from you, or about you, may include but are not limited to, the following:

The methods by which We collect your data include but are not limited to the following:

1. When you access our Website or Mobile Application or use any features of our Website or Mobile Application;
2. When you provide your Personal Information to us;
3. During the course of services provided to you by us;
4. Through your computer/device, once you have granted permissions to our Website or Mobile Application;
5. Through Our representatives;
6. Through use of cookies (also discussed below); or

You hereby agree, acknowledge and grant Your consent to Us to obtain information/data from You through the Website or Mobile Application, 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 Registrar and Transfer Agents (“RTAs”), KYC Registration Agency (“KRAs”) other third party business partners, to the extent required to provide the Stable Money Bonds Services on the Mobile Application and the Website, 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.

You acknowledge that We may keep records of communications, including phone calls received and made 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 Website or Mobile Application. However, all records are regarded as confidential. Therefore, such records will not be divulged to any third party, unless required by law.

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

We collect information that your browser/app sends whenever you visit our Website or Mobile Application, such as the Log Data. In addition, we may use third party services to collect, monitor and analyse such Log Data. This information is kept completely secure.

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 Stable Money Bonds Services on the Website and Mobile Application, 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, which may inter alia include:

1. Facilitating the Stable Money Bonds Services on the Mobile Application and Website provided by Us, including:
   • Setting up Your designated investment account and facilitating the processing of Your investment instructions which You may initiate through the Website or Mobile Application via Your designated account ("Transaction Instructions").
   • Maintaining a record of Your Transaction Instructions, transactions and holdings, generating and sending reminders, alerts, notifications to You for transactions, upcoming funds transfers, etc.
2. Verifying Your identity for the purposes of allowing You to avail of the Stable Money Bonds Services on the Website or Mobile Application.
3. Checking/ updating/ registering Your KYC details in centralized KYC databases KRA Databases.
4. Resolving Your queries, concerns and providing You with support in case of any issues during the use of the Stable Money Bonds Services on the Mobile Application or Website.
5. Informing You about any offers relating to the Stable Money Bonds Services on the Website and Mobile Application including sharing of marketing material with You.
6. Streamlining and customizing Your experience of using the Website and Mobile Application.
7. Informing You about the progress of and issues with, if any, pertaining to the Transactions Instructions initiated by You and the resolution thereof or relating to the Stable Money Bonds Services on the Website and Mobile Application availed by You.
8. To resolve any customer support related issues. To contact you via phone, whats app, SMS or email for appointments, technical issues, payment reminders, obtaining feedback and other security announcements;
9. Tracking, analyzing and maintaining information about Your use of the Website and Mobile Application.
10. Carrying out research, planning and statistical analysis.
11. Undertaking analytics for the purposes of developing or improving our products, Stable Money Bonds Services on the Website and Mobile Application, security, service quality, and advertising strategies.
12. Managing our infrastructure and business operations and complying with internal policies and procedures.
13. Conducting due diligence checks as may be required under applicable laws, regulations or directives.
14. Complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities.
15. Undertaking financial reporting, regulatory reporting, management reporting, risk management, audit and record-keeping activities.
16. Enforcing obligations owed to Us.
17. Enabling Us, and Bonds Issuers to communicate with You with respect to the products/services that You may have availed by or through Us. To send promotional and marketing emails from us or any of our channel partners via Whatsapp, SMS, email or third-party communication services.
18. Using Your information in other ways as required or permitted by law or with Your consent.
19. Collection of data by cookies which helps Us track, analyse and understand Your trends so as to enable Us to understand lacunas (such as slow response time on the Website and Mobile Application) and improve Your interactive experience of availing our Stable Money Bonds Services on the Website and Mobile Application, our design, features and functionalities.
20. Using Your information to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Terms, breach of our agreement with You or as otherwise required by law.
21. Disclosing Personal Information about You to our representatives, service providers and other third parties to comply with applicable laws and regulations. We reserve the right to disclose Your Personal Information to third parties in an anonymous or aggregate form, upon the consent of the User, to understand customer trends and patterns and manage and improve our business relationships. We provide Your Personal Information to our business partners, representatives and third-party processors to administer and process for the purposes notified to You in this Privacy Policy, and We may also share such details with third parties (such as auditors or legal advisors) to obtain professional advice. Any such processing will be governed by an agreement in the form required by law, preserving any and all of Your statutory data protection rights.
22. Disclosure or transfer of Your Personal Information with Courts and Government agencies in certain instances such as for the verification of identity, or for prevention, detection, investigation, prosecution, and punishment for offences, or in compliance with laws. You hereby consent to the disclosure or transfer of Your Personal Information in these instances.
23. Disclosure of Personal Information with our other corporate and/or parent/associate entities and the Affiliates to (i) help detect and prevent identity theft, fraud and other potentially illegal acts and cyber security incidents, and (ii) help and detect co-related/related or multiple accounts to prevent abuse of Stable Money Bonds Services on the Mobile Application or Website.
24. Additionally, while negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets, we may have to disclose our databases and information we have stored in the course of our operations, subject to execution of appropriate confidentiality agreements, and strict compliance with data security requirements.

You understand, acknowledge and expressly grant Us Your consent:

1. To share/ receive Your Personal Information and/or Non-Personal Information with/from Us/ affiliate entities/ business partners, for the purposes which are specified in this Privacy Policy including providing You with the Stable Money Bonds Services on the Website and Mobile Application, improving the existing Stable Money Bonds Services on the Website and Mobile Application, enhancing the user experience, building affluence scores/ user insights, analysing data for the introduction of new features, and as may be required to comply with any regulatory requirements and contractual obligations. We also reserve the right to disclose your Personal Information to third parties in an anonymous or aggregate form, to understand customer trends and patterns and manage and improve our business relationships.
2. 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.
3. To collect/ receive/ process/ use/ store certain Personal Information (including PAN, date of birth, residential status, etc.) that You may have shared with the Company in order to allow Us to provide the Stable Money Bonds Services on the Mobile Application or Website to You. Further, You expressly consent that certain Personal Information that may be shared by You with Us, including financial information (such as debit card details or other payment mode details), or Your information that may be collated by Us from the KRAs may be shared with the Company in order to facilitate the provision of the Stable Money Bonds Services on the Website and Mobile Application to You.
4. We may disclose Personal Information about you to our representatives and other third parties or with Courts and Government agencies in certain instances such as for verification of identity, or for prevention, detection, investigation, prosecution, and punishment for offences, or in compliance with laws. You hereby consent to disclosure or transfer of your Personal Information in these instances. We may also share such details with third parties (such as auditors or legal advisors) to obtain professional advice. Any such processing will be governed by an agreement in the form required by law, preserving any and all of your statutory data protection rights.

We, our third party service providers and our partners may send "cookies" to your computer or use similar technologies to enhance your online experience at our Website or Mobile Application. "Cookies" are files that can identify you as a unique customer and store your personal preferences as product preferences to tells us which site pages you have visited and in what order. We use cookies and other technical information to personalise your visit to the Website or Mobile Application, to analyse traffic on the Website or Mobile Application and to track user trends, patterns and selections for authorised download and for technical reasons connected with your use of our Website or Mobile Application.

Cookies can either be permanent (i.e. they remain on Your computer until you delete them) or temporary (i.e. they last only until you close your browser). We may store both temporary or permanent ‘cookies’ on Your computer/device to store certain data (that is not sensitive Personal Information). You can erase or choose to block these cookies from your computer. You can configure your computer’s browser to alert you when we attempt to send you a cookie with an option to accept or refuse the cookie.

We do not control the use of cookies by third parties.

We work to protect the security of Your Personal Information during transmission by using appropriate software, which encrypts the information You input. This encrypted information is stored on secure servers and data centres. Further, We ensure that the number of employees involved in the management of the data centre who have physical access to these computers is limited. Also, We use advanced security technology to prevent our computers from being accessed by unauthorized persons.

We have also implemented information security practices and standards and have in place information security programmes and policies containing managerial, technical, operational and physical security measures that are in compliance with the applicable laws including, so as to protect the information provided to Us from unauthorized access, use, modification, damage, disclosure or impairment. Further, We may from time to time use reasonable additional or alternative procedures to ensure the security and confidentiality of Your Personal Information through our Website and Mobile Application.

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.

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 Mobile Application or Website; and You do so at Your own risk.

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 Website or Mobile Application which is operated by third-party entities and is not controlled by, or affiliated to, or associated with Us unless expressly specified on the Website or Mobile Application.
2. We are not responsible for any form of transmission, whatsoever, received by You from any third-party website. Accordingly, We do not make any representations concerning the privacy practices or policies of such third-party entities or terms of use of such Other Websites, nor do We control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such Other Websites. The inclusion or exclusion does not imply any endorsement by Us of the Other Websites, the websites provider, or the information on such Other Websites. The information provided by You to such Other Websites shall be governed in accordance with the privacy policies of such Other Websites, and it is recommended that You review the privacy policy of such Other Websites prior to using such websites.

Notwithstanding anything to the contrary mentioned elsewhere in the Privacy Policy, 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. Retention of Your Personal Information and/or Non-Personal Information will also be applicable pursuant to cancellation/ deactivation/ non-subscription of Your designated investment account with Us.

1. We seek to provide reasonable assistance to cater to request(s) from You regarding the processing of Your Personal Information and the right to amend and withdraw permission to the processing/ use/ storing/ sharing of Your Personal Information. In accordance with applicable laws and as per the terms of this Privacy Policy, You may exercise the following rights:
   1. Access the information We hold about You, or get a copy of it in a portable (machine-readable) format or request Us to send it to a third party.
   2. Review or rectify the inaccurate Personal Information stored with Us.
   3. Withdraw Your consent to collect/ receive/ share/ process/ use/ store Your Personal Information that You had given Us for availing the Stable Money Bonds Services on the Website or Mobile Application and prevent further processing of Your Personal Information subject to the terms of this Privacy Policy. You may also withhold Your consent prior to the collection and processing of Your Personal Information and Non-Personal Information.
   4. Ask Us to update/delete Your Personal Information. However, You understand that the deletion of certain information may impact the Stable Money Bonds Services on the Mobile Application and / or Website being offered to You and the same may result in total suspension of the Stable Money Bonds Services on the Mobile Application or Website if the deleted information is of a category that is considered mandatory to provide the Stable Money Bonds Services on the Mobile Application or Website.
   5. Some of our Stable Money Bonds Services on the Mobile Application and Website allow You to upload, submit, store, send or receive content. When You upload, submit, store, publish, send or receive content to or through our Mobile Application and Website, You provide us with Your consent to utilise such content, including for our marketing purposes, subject to our Privacy Policy.

   Such content must not:

   1. Be harmful, harassing, blasphemous, defamatory, obscene, pornographic, paedophilic, libellous, invasive of another’s privacy, hateful or racially or ethnically objectionable, disparaging, and relating to, or encouraging money laundering or gambling
   2. Harm minors in any way.
   3. Infringe any patent, trademark, copyright or other intellectual property rights.
   4. Deceive or mislead the reader about the origin of such messages or communicate any information that is grossly offensive or menacing in nature.
   5. Contain software viruses or any other programs designed to interrupt, destroy or limit the functionality of another computer or mobile device.
   6. Threaten the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign states, or public order.
   7. Cause the incitement to commit any offence or prevent the investigation of any offence.
   8. Be insulting to any other nation.
   9. Impersonate another person.
   10. Violate the provisions of the Information Technology Act, 2000 and rules and regulations thereunder or any other applicable laws.
2. You can exercise any of the aforementioned rights by submitting a request to [email protected]
3. You understand that these rights are limited in some situations, such as, where We are legally or otherwise bound to process/ retain/ share/ disclose Your Personal Information. This may also affect our ability to provide You the Stable Money Bonds Services on the Mobile Application or Website and therefore may lead to discontinuation of the Stable Money Bonds Services on the Mobile Application or Website for You.

You are responsible for maintaining the accuracy, truthfulness, correctness and completeness of the Personal Information You provide Us, and our associate/affiliate entities/ third party service providers like KRAs and RTAs, that is necessary for providing the Stable Money Bonds Services on the Mobile Application and Website to You. You shall hold harmless and indemnify Us, the Affiliates and our associate/affiliate companies/ third party service providers like KRAs and RTAs 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/ third party service providers like KRAs and RTAs. If Your Personal Information is wrong/inaccurate, You shall correct, delete inaccuracies, or amend Your information by making the necessary change on the information on the Mobile Application and Website or contact us at [email protected].

We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, We shall update the same on the Mobile Application and Website. Please revisit the Mobile Application and Website periodically for the latest information on our privacy practices. Once posted, those changes are effective immediately unless stated otherwise. Continued access or use of the Mobile Application and Website or availing of the Stable Money Bonds Services on the Mobile Application or Website constitutes Your acceptance of the changes to the amended Privacy Policy. However, if You do not agree with the changes, please do not continue to use the Mobile Application and/or Website or avail of the Stable Money Bonds Services on the Mobile Application or Website or submit Your Personal Information to Us and notify Us about Your disagreement over an email to [email protected]. Subsequently, upon confirmation from the Company, Your access to the Mobile Application and Website will be suspended.

In accordance with Information Technology Act 2000 and rules made thereunder, the name and contact details of the Grievance Officer are provided below for Your reference

Name: Pranav Iyer

Email: [email protected] or [email protected]

Address: Third floor, Block A, Stable Money, Bhive HSR Premium Campus, Krishna Reddy Industrial Area, Kudlu gate, Bommanahalli, Bangalore, Karnataka, India, 560068