“Personal Data” has the definition set forth in The Personal Data Protection Bill, 2019. This notice covers our use of your personal data arising from use of the Etor website (www.etorexchange.in) as well as registering/subscribing/buying/using our apps, products and services and signifies that you accept and agree to our Policies. If you have any questions or need any further clarity, please get in touch. Contact details are set out below in the Contact Us section.
a. PAN Card Details.
b. Aadhar Card Details.
c. Contact Number.
d. Email ID.
We collect the Personal Data you provide directly to us or which we generate when you open a Etor Account, perform any transactions on the Etor Platform, or use other Etor Services or our website. This may include:
• Contact information, such as name, home address, and email address;
• Account information, such as username, password, account settings and preferences;
• Financial information, such as bank account numbers, bank statement, and trading information;
• Identity verification information, such as images of your government issued ID, passport, national ID card, or driving licence;
• Residence verification information, such as utility bill details or similar information;
• Information regarding the way in which you use our services, such as when you use our services and the specific services used; and
• Information relating to communications with us, whether through the Etor website or via e-mail, over the phone or via any other medium.
We also automatically collect certain computer, device and browsing information when you access the Etor website or use Etor Services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:
• Computer or mobile device information, including IP address, operating system, network system, browser type and settings; and
• Website usage information.
Finally, we may collect Personal Data from third-party partners and public sources, which include:
• Reputational information;
• Financial information;
• Business activities of corporate customers.
We use third-party service provider(s), to assist us in better understanding the use of our website. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors’ interests in our website and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using information they receive from our website other than to assist us.
If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features of our website or services, such as logging into your Etor Account or making transactions. Your use of our website or service with a browser that is configured to accept cookies constitutes an acceptance of our and third-party cookies.
We collect and use your information for a variety of reasons. We need some information to enter into and perform our contract, for example your contact and payment details. Some information processing is required by law due to our anti-fraud screening obligations or in the public interest such as making sure we verify our customers’ identities. Some information is processed because you have given your consent to that, which can be withdrawn in your account preferences and settings. Other information we collect and use because we have legitimate business interests, having taken into account your rights, interests and freedoms.
We may use your Personal Information to:
• Create and administer your Etor account and generally for accounting, billing, maintenance of legal documentation and claim and dispute management. Related processing operations are necessary for the performance of a contract with you (or to take steps at your request prior to entering into a contract), and for compliance with legal obligations to which we are subject;
• Process your Etor transactions. Related processing operations are necessary for the performance of a contract with you and for compliance with legal obligations to which we are subject;
• Verify your identity in accordance with applicable know-your-customer, money laundering and other financial sector legislation or regulations, including as required for compliance with the Etor Anti Money Laundering policy, as well as address other law enforcement needs as more fully described in our Terms of Service, and generally as required for compliance with legislation and regulations applicable to Etor;
• Personalise your Etor Services experience. Related processing operations are necessary for purposes of our legitimate interests (that is, improving our services);
• Analyse Etor website usage and improve our website as well as website offerings. Related processing operations are necessary for purposes of our legitimate interests (that is, improving and promoting our services);
• Help us respond to your customer service requests and support needs. Related processing operations are necessary for the performance of a contract with you, and for purposes of our legitimate interests (that is, improving our services and offering you the best experience);
• Contact you about Etor Services. The email address you provide may be used to communicate information and updates related to your use of the Etor Services.
We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our services to you based on a credit check/risk profiling. Depending on the outcome of the credit check/risk profiling, a decision will be reached automatically as to whether we are able to provide products or services to you based on your credit worthiness.
Other significant automated decision-making that uses your personal data may also be employed, to protect accounts and to uphold our Terms of Service. In addition, if the information provided during any identity verification or onboarding process (including self-reported information, information that is derived from your ID document, proof of address, or any other document provided by you, or your IP address or browser location information) suggests that you may be in breach of our Terms of Service or may have provided false or inaccurate information, your account may be automatically restricted. During an account lockout, you may be unable to view your positions, make any trades, or open or close any orders.
We may also occasionally communicate company news, updates, promotions and related information relating to similar products and services provided by Etor. We may also administer a contest, promotion, survey or other site features as will be more explained on the website.
We may share personal data with third parties to help us with our marketing and promotional projects, or sending marketing communications.
If you want to opt out of receiving promotional and marketing emails, text messages, post and other forms of communications from us or our promotional partners in relation to which you might receive in accordance with this section, you can best opt out by using one of the following ways:
• Log into your account and update your profile;
• Click 'unsubscribe' at the bottom of an email we sent you;
• contact us at firstname.lastname@example.org to opt out.
If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, survey requests in respect of products and services we have provided to you after you reserve from us, reservation confirmations or respond to your inquiries or complaints, and similar communications.
To the extent required by law, we aim to carry out balancing tests when significant data processing activities are justified on the basis of our legitimate interests, in particular:
• to provide services you have requested;
• to monitor, improve and protect the services on our website and apps, in particular by looking at how they are used, testing alternatives (e.g. by “A/B testing”, and running “beta” version trials), and by learning from feedback and comments you provide;
• to personalise our website, apps and services;
• by publishing de-identified records of market data, including trading records, for third party monitoring and research purposes;
• to monitor customer accounts to prevent, investigate and/or report misconduct such as spam, misrepresentation, security incidents, market manipulation or crime (such as fraud), in accordance with applicable law, and to cooperate with authorities seeking to do the same;
• to investigate any complaints received from you or from others;
• in connection with legal claims, compliance, regulatory or investigative purposes (including disclosure in connection with legal process or litigation); and
• to invite individuals to take part in market research and beta tests.
No personal information of any user is being disclosed for any purpose. Stored personal information is available only to the user for editing purposes and to customer service personnel, verification department and to administrators and consultants, and third-party entities and service providers who are bound by non-disclosure agreements.
However, we do share information with law enforcement and government officials when we are compelled to do so by a court order or similar legal procedure.
You also agree that Etor shall be free to transfer/disclose any information shared by you with us, to a related party or to an affiliate or to any entity controlled by the promoters of Etor. We may also transfer your information during the sale of assets or business to another company, demerger into another company while getting acquired by another company or getting merged with another company.
Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data. Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide Etor Services or as required by law. Etor’s third-party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law.
We use a variety of security measures to ensure the confidentiality of your Personal Data, and to protect your Personal Data from loss, theft, unauthorised access, misuse, alteration or destruction. These security measures include, but are not limited to:
◦ Password protected directories and databases;
◦ Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Intercom securely;
◦ PCI Scanning to actively protect our servers from hackers and other vulnerabilities. All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorised Etor personnel are permitted access to your Personal Data, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.
◦ How long you have been a Etor member;
◦ Whether there are contractual or legal obligations existing that require us to retain the data for a certain period of time;
◦ Whether there is any ongoing legal or financial claim that relates to your relationship with us;
◦ Whether any applicable law, statute, or regulation allows for a specific retention period; and
◦ What the expectation for retention was at the time the data was provided to us.
Although our website and apps only look to include quality, safe and relevant external links, users should always adopt a policy of caution before clicking any links to non-Etor websites or apps. We cannot control, guarantee or verify their contents. They will have their own policies and practices, for example with regard to privacy and personal data, and you should acquaint yourselves with those before further engaging with those third party websites or apps.