Tavaga Advisory Services Private Limited is the author and publisher of the Tavaga Mobile Application (“App”), through
When you share information with us, we are able to make our services even better. As you use our Services, we want
you to be clear on how we’re using your information and the ways in which you can protect your privacy.
a. Section 43A of the Information Technology Act, 2000 (“IT Act”);
b. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal
Information) Rules, 2011 (“SPDI Rules”); and
c. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
(i) What information we collect;
(ii) How we collect and use that information;
(iii) How you can provide information selectively, and how you can access and update this information; and
(iv) How we process, share and protect your information
The App is owned and operated by Tavaga Advisory Services Private Limited, whose office is at WeWork, C-20, G Block,
Bandra-Kurla Complex Mumbai MH 400051.
BY ACCESSING OR USING OUR APP OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE THE CAPACITY
TO ENTER INTO A LEGALLY BINDING CONTRACT AS PER APPLICABLE LAW APPLYING WITHIN THE JURISIDICTION OF THE REPUBLIC
OF INDIA, IN PARTICULAR, THE INDIAN CONTRACT ACT, 1872, AND CONSEQUENTLY, WILL BE DEEMED TO HAVE READ, UNDERSTOOD
YOU HEREBY CONSENT TO OUR COLLECTION, USE, SHARING, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY
OUR SOLE DISCRETION, AT ANY TIME, AND ANY CONTINUED USE OF THE APP BY THE USER FOLLOWING ANY SUCH AMENDMENTS TO
ARE ACCESSING OR USING THIS APP FROM AN OVERSEAS LOCATION, YOU DO SO AT YOUR OWN RISK, AND SHALL BE SOLELY LIABLE
FOR COMPLIANCE WITH ANY APPLICABLE LOCAL LAWS.
PROVIDED ON THE APP, OR PROVIDE US WITH ANY OF YOUR INFORMATION.
2. Information Collected and Method of Collection
We collect the following types of information about you, both through offline documentation that you may fill, as
well as when you use our App: demographic information, behavioral information, and indirect information, (as defined
below, and collectively, “Information”).
Additionally, we also collect account information and personal information (as defined below) from you. We collect
your information and account information either directly from you through forms on the App or indirectly by using
different technologies. We collect personal information (as defined below) only directly from you.
We may collect from you, information which is not unique to you and refers to selected population characteristics
(“Demographic Information”) including age, gender, location and occupation.
We may also collect information about how you use the App and information about your mobile device and software
including usage statistics, traffic data, your IP address, browser and operating system type, domain names, access
times, locations, your previous orders and transactions including the product and pricing details, transaction
information and payment and browsing history (“Behavioural Information”).
Your use of certain third party services on the App also requires us to collect such information as is considered
necessary for that purpose (“Indirect Information”).
While we may collect demographic information, behavioral information and indirect information when you access
or use our App, we only collect account information and personal information from you, when you choose to use or
avail our optional service.
In order to avail or use our optional service, you are required to provide us with your details, including but
not limited to: your name; date of birth; mobile number; email address; PAN number; a pin code created by you,
and details required for your KYC forms and the account opening form (collectively, “Account Information”).
The IT Act and the SPDI Rules regulate the collection, usage, retention and disclosure of personal information,
which is defined under the SPDI rules as any information that relates to a natural person, which, either directly
or indirectly, in combination with other information available or likely to be available to a body corporate, is
capable of identifying such person.
The SPDI rules further define “Sensitive Personal Data or Information” (“SPDI”) of a person as personal information
about that person relating to:
ii. Financial information such as bank accounts, credit and debit card details or other payment instrument details;
iii. Physical, physiological and mental health condition;
iv. Sexual orientation;
v. Medical records and history;
vi. Biometric information;
vii. Any detail relating to the above clauses as provided to the body corporate for providing services; and
viii. Any of the information received under above clauses by body corporate for processing, stored or processed
under lawful contract or otherwise.
In addition to your account information, you will also need to provide us with your bank account details (in respect
of the bank account you wish to use to make or receive any payments related to any transactions).
Such bank account details, including details submitted pursuant to your KYC form (“Personal Information”), correspond
All account information and personal information is provided by you to us voluntarily. Collection, use and disclosure
of personal information requires your express consent. By providing us with personal information, you are providing
us with your consent to our use, collection and disclosure of the personal information.
You may choose to not provide us with any or all information included under account information and personal information,
but in the event that you do so, we will be unable to provide you with our optional service.
3. Use of Information
We use your information for the following purposes:
a. To operate and improve the App in order to foster a positive user experience and to improve our business as
b. Analysing data, tracking trends, building algorithms, creating databases for rating systems, recommendations
d. For non-targeting reasons such as frequency capping, compliance, billing, ad reporting or delivery, market research
or product development purposes;
e. To conduct audits and quality assessment procedures; and
f. To analyse the use of our resources, troubleshooting problems and improving our services, by using the information
regarding your mobile device and software.
In addition to the above, we also use your information, account information and personal information for the following
a. To provide our optional service to you, including by creating, retaining and analyzing your investment profile,
list, parameters and other relevant information;
b. To facilitate the opening of an account for the undertaking of any transactions chosen by you, by:
(i) Obtaining your KYC details from KYC Registration Agency, if you have a record with KYC Registration Agency,
or obtaining any KYC details provided to us by you to process your transaction account; and
(ii) Communicating your account information and personal information to the Broker, who will undertake the account
c. To provide any and all information that may be required by us or the Broker, from time to time, in compliance
with existing legal norms and regulations, including but not limited to contact information, address and tax related
information and any information required under existing or future KYC norms and laws or as may be deemed necessary
to authenticate your profile or any action taken using your account;
d. To comply with applicable law;
e. Contacting Users for offering new products or services;
f. To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving
g. To respond to any queries that you may have, and to communicate information to you, including notifications
of any promotions or alerts, any updates to the App, or the introduction of any future fees or charges that we
may collect at the time for the provision of our services to you;
h. To contact you from time to time to record your valuable feedback on our services, as they currently stand,
and/or any potential services that may be offered in the future. (Collectively, the above constitute “the Purposes”).
If you wish to opt out of receiving non-essential communications such as promotional and marketing-related information
regarding the services, please email us at firstname.lastname@example.org.
4. Disclosure of the information
We disclose your information, account information or personal information, as the case may be to third parties in
the manner specified below:
a. Disclosing your information, account information and personal information to companies and individuals who are
authorized by us to perform functions, including our broker;
b. We may share your information and account information with our partners, affiliates, investors, stakeholders
or potential associates in an anonymized and aggregate manner, so that they too may understand how users use our
App, and enable us to create a better overall experience for you;
c. We also share aggregated anonymous information about Users with our clients, partners, other App Users, and
other third parties so that they may be aware of the nature and number of Users using the App, in order for them
to be able to serve advertisements and other kinds of marketing information that may be relevant for you on our
d. We may disclose and transfer your information, account information and personal information to a third party
who acquires, or may potentially acquire, our business, whether such acquisition is by way of a merger, consolidation
or purchase of all or a substantial portion of our assets;
e. We may transfer information, account information and personal information to a third party, including persons
outside India, to improve the Services; and
f. We will disclose your information, account information and personal information if legally required to do so,
pursuant to an order from a governmental entity or in good faith. We will disclose the information to:
i. Conform to legal requirements or comply with legal process;
ii. Protect our rights or property or our affiliated companies;
iii. Prevent a crime or protect national security; or
iv. Protect the personal safety of users or the public.
Such third parties may include:
• Our associates, affiliates or related entities;
• Any of our agents, contractors or third party service providers that process or will be processing your information,
and relevant account information on our behalf, including but not limited to those which provide administrative
or other services to us such as mailing houses, telecommunication companies, information technology companies and
data centres; and
• Third parties, such as our broker, to whom disclosure by us is for one or more of the purposes and such third
parties would in turn be collecting and processing your information, account information and personal information
for one or more of the purposes.
Subject to applicable law, we may at our sole discretion, transfer personal information to any other body corporate
(as defined under the information Technology Act, 2000) that ensures at least the same level of data protection
as is provided by us under the terms hereof, located in India or any other country.
By using the App, you accept the terms hereof and you hereby consent to the storage and processing of personal
information in any of the above locations. By continuing to use the App, you provide your consent for transfer,
sharing and disclosure of such information, account information and personal information by us in accordance with
Any third party to which we transfer or sell our assets, merge or consolidate with, will have the right to continue
to use the information, account information and personal information provided to us by you, in accordance with
5. Third Party Links
The App may include hyperlinks to various external websites, and may also include advertisements, and hyperlinks
to applications, content or resources (“Third Party Links”). We have no control over such Third Party Links present
on the App, which are provided by persons or companies other than us. You acknowledge and agree that we are not
responsible for any collection or disclosure of your information by any external sites, applications, companies
or persons thereof. The presence of any Third Party Links on our App, cannot be construed as a recommendation,
endorsement or solicitation for the same, or any other material on or available via such Third Party Links.
You further acknowledge and agree that we are not liable for any loss or damage which may be incurred by you as
a result of the collection and/or disclosure of your information via Third Party Links, as a result of any reliance
placed by you on the completeness, accuracy or existence of any advertising, products services, or other materials
on, or available via such Third Party Links. This will include all transactions, and information transmitted therein,
between you and any such third party sites or applications or resources, such transactions are strictly bi-partite.
We shall not be liable for any disputes arising from or in connection with such transactions between you and the
aforementioned third parties.
Such third party websites, and external applications or resources, accessible via the Third Party Links may have
their own privacy policies governing the collection, storage, retention and disclosure of your information that
you may be subject to. We recommend that you exercise reasonable diligence, as you would in traditional offline
channels and practice judgment and common sense before committing to any transaction or exchange of information,
6. Changes to your information
You may review, correct, update, change or delete your account information and personal information on the App. Log
into your account and you will be able to access and update your account information and personal information.
You can delete any part of the account information and personal information or request us to delete your account
information and personal information, and we will comply with such requests within a reasonable time, unless we
are required to keep certain information for legal purposes.
Should you choose to delete your account information and/or personal information, or modify it in a way that is
not verifiable by us, or leads to such account information or personal information being incorrect, we will be
may be regarded as the User seeking to discontinue receipt of our Services.
We reserve the right to verify and authenticate your identity and your account information and/or your personal
information in order to ensure accurate delivery of Services. Access to or correction, updating or deletion of
your account information or personal information may be denied or limited by us if it would violate another person’s
rights and/or is not otherwise permitted by applicable law.
7. Security of your information
We endeavor to maintain physical, technical and procedural safeguards that are appropriate to protect your information
against loss, misuse, copying, damage or modification and unauthorized access or disclosure. Some of the security
measures adopted by us are:
• We review our information collection, storage and processing practices, including physical security measures,
to guard against unauthorized access to systems; and
• We restrict access to personal information, to our employees and agents who need to know that information in
order to process it for us, and who are subject to strict contractual confidentiality obligations, and may be disciplined
or whose relationship with us may terminate if they fail to meet these obligations.
Our security management standards are in compliance with ISO 27001. ISO 27001(Information Technology – Security
Techniques – Information Security Management System - Requirements) is a widely recognized international security
management standard that specifies security management best practices and comprehensive security controls following
the ISO 27002 best practice guidance. Our compliance with ISO 27001 demonstrates our commitment to information
security at every level.
No employee or administrator of the Company will have knowledge of your password or PIN code. It is important for
you to protect against unauthorized access to your password, your PIN code and your mobile phone. Be sure to log
off from the App when finished. We do not undertake any liability for any unauthorised use of your account and
password. If you suspect any unauthorized use of your account, you must immediately notify us by sending an email
to email@example.com. You shall be liable to indemnify us due to any loss suffered by us due to such unauthorized
use of your account, password or PIN code.
Further, we shall not be responsible for any breach of security or for any actions of any third parties or events
that are beyond our reasonable control including but not limited to acts of government, computer hacking, unauthorised
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.
Retention of Information
We will also put in place measures such that your account information and personal information, which is in our
possession or under our control, is destroyed and/or anonymized as soon as it is reasonable to assume that (i)
the Purpose for which that account information or personal information were collected is no longer being served
by the retention of such account information or personal information; and (ii) retention is no longer necessary
for any other reason.
If you wish to cancel your account, or request that we no longer use your account information and personal information
to provide you services, contact us at firstname.lastname@example.org.
If you wish to delete your account, and thereby discontinue using our optional service, you may do so at any time,
We, however, reserve the right to retain, store and use your information, account information or personal information
or content for our business purposes, whether such information or your account has been deleted or not. After a
period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for
us to provide our services effectively, but our use of the anonymized data will be solely for analytic purposes.
Please note that your withdrawal of consent or cancellation of account may result in us not being able to provide
you with our services, or terminate any existing relationship that we may have with you. Please also note that
uninstalling the App will not result in termination of your use of the App or services.
effect from the date of such update, change or modification. If you continue to access or use the App even after
9. Cookies and other tracking technologies
We utilize “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example,
to collect information about activity on the App. Some cookies and other technologies may serve to recall information
previously indicated by a user. Most browsers/mobile settings allow you to control cookies, including whether or
not to accept them and how to remove them. You may set most browsers/mobile application to notify you if you receive
a cookie, or you may choose to block cookies with your browser/mobile applications.
Tracking technologies may record information such as internet domain and host names, internet protocol (IP) addresses,
browser software and operating system types, stream patterns, and dates and times that our App are accessed. Our
At all times, you may refuse all cookies on your mobile application by changing your mobile settings to the extent
permissible on your device. However, by doing so, you may not be able to use certain features on the mobile application
you visit or take full advantage of all the mobile application offerings and interest-based advertising. You can
remove cookies by following directions provided in your mobile’s “help” file.
We cannot ensure that all of your information, account information or personal information will never be disclosed
privacy, we do not promise, and you should not expect, that your information or private communications will always
remain private. As a user of the App, you understand and agree that you assume all responsibility and risk for
your use of the App, the internet generally, and the information you post or access and for your conduct on and
off the App.
You agree and undertake to indemnify us in any suit or dispute by any third party arising out of disclosure of information
by you to third parties either through our App or otherwise and your use and access of websites, applications and
resources of third parties. We assume no liability for any actions of third parties with regard to your information,
account information or personal information which you may have disclosed to such third parties.
any other clauses herein except where otherwise expressly indicated or indicated by the context of the Privacy
The decision or declaration that one or more of the clauses are null and void shall have no effect on the remaining
13. Grievance officer and contact information
In accordance with the IT Act and rules made there under, the name and contact details of the Grievance Officer are
You may write to him at the following address:
Mr. Nitin Mathur
WeWork, C - 20, G Block, Bandra Kurla Complex, Mumbai, Maharashtra 400051.
employ all commercially reasonable efforts to address the same.