General:

1. Zayment Solutions Private Limited (‘Zayment’, ‘Us’, ‘Our’, ‘We’) is committed to the protection of personal information provided by the users (‘You’, ‘User’, ‘Your’) to Us. You agree that Your use of the website, mobile application, other services (‘Platform’) implied Your consent to the collection, retention and use of Your personal information in accordance with the terms of this privacy policy (‘Privacy Policy’).

2. This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents / records in various statutes as amended by the Information Technology Act, 2000. This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between You and Us.

3. We take the privacy of Our Users seriously. We are committed to safeguarding the privacy of Our Users while providing a personalized and valuable service.

4. Your access to the contents available through the Platform is conditional upon Your approval of this Privacy Policy which should be read together with the terms and conditions of use (“Terms”). You acknowledge that this Privacy Policy, together with our Terms, forms Our agreement with You in relation to Your use of the Platform. Should You disagree with any of the terms contained herein, please cease using the Platform.

Information We Collect: We gather various types of information:

1. During account creation and registration (Your Account Information): When You create and register Your account, We request the following data:

   1. Name

   2. Gender

   3. Age

   4. Nationality

   5. Email address

   6. Mobile number

   7. Address

   8. Know Your Customer (‘KYC’) documents, such as a government-issued identity proof

   9. A photograph (live or uploaded)

   10. Any other details We may be required to collect under Applicable Law.

2. During Your use of the Platform: We may automatically receive and collect technical information about your computer or device. This includes, but is not limited to, Your IP address, computer operating system, time-zone, browser type, and browser plug-in details, due to communication protocol settings on the internet. We also collect information about the pages you view, the web addresses from which You link to Our Platform, the time spent on specific pages, download errors, and page response times. This data helps Us to enhance Our product and improve Your experience on the Platform. 

3. Communication records: We may maintain records of communications, including telephone calls, chats, and conversations You have with Our customer service representatives. This information is collected to ensure the quality of service provided and to facilitate product improvement.

4. Optional information: From time to time, We may include optional requests for additional information to customise the Platform for You, particularly to deliver personalised content. The collection, use, and disclosure of such additional personal information will be conducted in accordance with this Privacy Policy and other Applicable Law.

5. Information from third-party sources: We may also obtain Your personal information from third-party sources. These include public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, or social media platforms, primarily to comply with applicable laws and regulations.

Reasons for Collecting Your Account Information:

1. We collect, process, and retain the aforementioned data attributes to deliver the Platform and its associated Services to You, and to comply with Applicable Law. Information collected by Us is processed and disclosed solely for the following purposes:

   1. to register You as a User on the Platform

   2. to facilitate the creation of Your Wallet

   3. to enable transactions from Wallets, including for Platform-related services

   4. to meet contractual obligations arising from agreements signed with vendors who assist in the operation, development, and hosting of the Platform

   5. to complete KYC-related verification processes, prevent fraud and fraudulent activities, and comply with Applicable Law, including money-laundering and anti-terror financing laws

   6. to fulfil Our obligations stemming from requests You make concerning the Services We provide on the Platform

   7. to comply with any filings, returns, or statements required under Applicable Law, including relating to taxation

   8. to comply with any information requests made by competent authorities as per provisions of Applicable Law

   9. to enhance the Platform’s functionality and to customise Your future experience with Us

   10. to ensure that transactions facilitated by the Platform are smooth and seamless

   11. to conduct research, statistical analysis, and gather information for business-related activities, such as determining visitor numbers and transactional details. We may share the outcome of this research in an aggregated or non-personally identifiable form with third-parties and affiliates

   12. to communicate with You regarding the Services We offer

   13. to display details about Your portfolio, transactions, trades, and their features available on the Platform through the mobile-based application and website

   14. to address any grievances, complaints, or queries raised by You

   15. to ensure that all Users comply with the provisions of Our Terms and Conditions and this Privacy Policy.

2. We will seek Your permission if We intend to collect, process, or use Your information for any other purpose not listed above.

Disclosure of Your Account Information: 

1. We may share Your information with Our trusted partners and third parties who assist in providing the Platform to You. We may also share aggregated, non-personally identifiable information publicly and with Our partners. Your information may also be used to perform analytics and conduct market research to analyse traffic patterns.

2. We may also disclose Your Account Information in any of the following cases, which include, but are not limited to:

   1. as required by Applicable Law to comply with a judicial order, executive order, or requirements by a law enforcement authority;

   2. if the provision of desired features on the Platform necessitates the disclosure of Your Account Information;

   3. if we believe in good faith that disclosures are necessary to comply with legal requirements, ensure the safety of others, or investigate fraud or crime.

   4. if we (or our affiliates) are involved in a merger, acquisition, or sale of substantially all of Our assets or equity. In such instances, information will be disaggregated to the extent possible and will be subject to the execution of appropriate non-disclosure agreements and binding privacy undertakings.
      https://onramp.money/assets/privacyPolicy.pdf
      
      

Retention of Your Account Information: 

1. We store Your Account Information for a pre-determined period based on the following criteria:

   1. Statutory and legal requirements.

   2. Industry guidelines.

   3. The use of de-identified or pseudonymised data sets in an aggregated format for scientific, statistical, or historical purposes.

2. We retain Your Account  Information for no longer than is necessary, and as may be required by law. Should We need to retain Your Account Information for a longer period, We will inform You prior to the extension of the storage period and seek Your explicit consent to extend the retention period. However, We may archive and/or retain some information for legal purposes. Any other information processed by us for analytical purposes will only be processed on an aggregated or non-identifiable basis. For any corrections or updates to information You have provided, please write to us at support@endl.app.

How We Protect Your Information:

1. Your personal data is maintained by Is in electronic form. We implement all necessary precautions and employ reasonable security practices and measures, including certain managerial, technical, operational, and physical security controls that are commensurate with the information being collected and the nature of Our business.

2. Specifically, Our security infrastructure, designed to safeguard Your Account Information against loss, unauthorised access, destruction, use, processing, storage, modification, or de-anonymisation, will at all times adhere to industry standards. We restrict access to Your Account Information to Our employees, contractors, and agents who require that information to process it. Anyone with this access is subject to strict contractual confidentiality obligations.

3. We prioritise the privacy and confidentiality of our User’s Account Information. Unless disclosure is legally compelled, any communication between You and Us during the onboarding process or while using Our Platform is confidential. This includes, but is not limited to, conversations via email, phone calls, or video conferences, and any documentation or information shared for the purpose of troubleshooting, support, or enhancement of Your experience on the Platform.

4. In the event that any information under Our control is compromised due to a breach of security or any other unforeseen event, We will take all reasonable steps to resolve the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps according to applicable rules and regulations.

Links to Other Web Sites and Services: We are not responsible for the practices employed by websites or services linked to or from the Platform, nor for the information or content contained therein. Please remember that when You use a link to navigate from our Service to another website, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. We urge you to read those rules and policies before proceeding.

International Data Transfer: 

1. Your information may be transferred to and stored in locations outside the territory in which We may be additionally operational and where the Platform is available on app stores. We will only undertake such transfers when the destination jurisdiction provides an adequate and appropriate level of protection, where the transfer is lawful, and only when it is required for Us to meet Our contractual and statutory obligations, and when the laws of your country permit us to do so. For clarity, the information that may be transferred outside is such information and in such a manner as permitted by Applicable Law to be sent to foreign jurisdictions.

2. When we transfer Your personal data from your 'Home Country' (the country, state, and city in which You are present) to an 'Alternate Country' (another country, state, and city), We will comply with Our legal and regulatory obligations concerning Your personal data, including establishing a lawful basis for transferring personal data and implementing appropriate safeguards to ensure an adequate level of protection for the personal data. We will also ensure that the recipient in the Alternate Country is obligated to protect your personal data at a standard of protection comparable to that under applicable laws. Our lawful basis for such transfers will either be based on consent or one of the safeguards permissible by law. For the transfer of data outside the EEA, We will adhere to adequate safeguards mandated under the GDPR. We ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws and contractual obligations placed on the recipient of the data (such as model contractual clauses).

Changes to this Privacy Policy: We make periodic changes to this Privacy Policy. The new terms will be posted on this page, and You will be required to read and accept them to continue Your use of the Platform and of its associated Services.

Contact Information For any further information, grievances, concerns, or clarifications, please do not hesitate to contact us at support@endl.app.