This document is an electronic record in terms of the Indian Contract Act, 1872, the Information Technology Act, 2000 and rules 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 and by clicking on the ‘Proceed’ button, you agree to be legally bound by this privacy policy, which is to be read with the Terms of Use at Terms of Use .
Thank you for choosing to be part of our community at Famli Technology Products Private Limited (“Famli,” “we,” “our,” or “us”). When you visit the website domain at www.famlilife.com or any application and/or interface for mobile and handheld devices that Famli may own and operate in the future (referred to collectively as the “Famli Platform” or “Platform”) and access, visit or use any products, and services provided by us (“Services”), we may collect personal information from you. Our team is committed to protecting your personal information and your right to privacy in accordance with applicable laws. The term “User”, “client” or “you” refers to the users of Famli Platform or the Services on the Platform.
In this privacy policy (“Privacy Policy”), we seek to explain to you (i) what information we collect; (ii) how we use it; (iii) your rights in relation to it; and (iv) security processes maintained by us in relation to the same. This Privacy Policy applies to all information collected through our Services (which, as described above, includes our Platform), as well as any related services, sales, or events. This Privacy Policy constitutes a legal agreement between you, as a user of the Services and/or the Platform, and Famli, and this Privacy Policy shall be enforceable against you.
Please carefully go through this Privacy Policy prior to accessing the Platform or availing Services using the Platform or submitting any personal information on the Platform. If a User continues to browse and use the Platform and/or avail Services, the User irrevocably and unconditionally is agreeing to comply with, abide by and be bound by all the obligations as stipulated in this Privacy Policy, read with our Terms available at Terms of Use and any other applicable policies referred to herein or made available on the Platform. You agree and consent to the collection, transfer, use, storage, disclosure and sharing of your information as described and collected by us in accordance with this Privacy Policy.
You represent and warrant that you have the right, authority and capacity to enter into this Privacy Policy (on behalf of yourself and/or, as applicable, the entity that you represent) and that the consent so given constitutes free, specific, informed, unconditional and unambiguous consent for the purpose of applicable law. If the individual entering into this Privacy Policy or otherwise accessing or using the Platform or Services is doing so on behalf of, or within his or her capacity as a representative, agent or employee of an entity, such individual and such entity agree that you represent and warrant that the individual entering into this Privacy Policy has the power, right, authority, and capacity to enter into this Privacy Policy on behalf of such entity. If you do not agree to be bound by this Privacy Policy or if you are an individual under the age of 18 (eighteen) or your access to or use of the Platform or the Services is illegal or prohibited under applicable law, you may not access or use the Platform or the Services. IF YOU DO NOT AGREE TO BE BOUND BY THIS PRIVACY POLICY, PLEASE DO NOT USE THE PLATFORM OR SERVICES.
We collect personal information that you voluntarily provide to us when you register on the Platform, express an interest in obtaining information about us or our Services, when you participate in activities on the Platform or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Platform, the choices you make and the products and features you use. The personal information we collect may include the following:
1. Personal information voluntarily provided by you:
(i) Registration Information: Data such as name, details of the family members (such as their names, age, contact details etc.), nationality, contact details, email address, gender, date of birth, age, marital status, contact details, organization name, organization email ID, demographic information such as addresses and pin code, permanent account number (PAN), Aadhar number, passport details, driving license details, voter ID, and other government issued identification numbers, photo identity, biometric data (including but not limited to fingerprints and/or facial recognition data), business and employment related information including employer details, designation, income information, and employment records.
(ii) Content: Data provided by you to us voluntarily while using the Services, for instance name, contact details, email address, demographic information, social media information about any individual identified by you in relation to the Services, emails in your inbox.
(iii) Payment: Data necessary to process your payment if you are making purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.
(iv) SMS Data Access and Processing: Subject to your explicit consent, we may access, store, transfer, and process your SMS and WhatsApp data to facilitate financial transactions and services, including but not limited to payment processing, OTP verification for secure logins, security authentication, bill payment confirmations, service notifications, transaction alerts, and other financial services-related communications, ensuring seamless and secure functionality of the Platform and Services. We may utilize both SMS and WhatsApp channels for delivering OTPs, payment confirmations, service notifications, and other communications necessary for the provision of the Services.
(v) Other information: Such as when you fill in a form, respond to surveys, participate in promotions, communicate with our support team and other members, import or manually enter address book contacts and / or emails.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. You represent and warrant that you have permission to provide that all the above information to Famli for the purposes described in this Privacy Policy.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. You represent and warrant that you have permission to provide that all the above information to Famli for the purposes described in this Privacy Policy.
2. Information we collect from you automatically:
(i) Log Data & Technical Information: Any information gathered through various technologies that may employ cookies, web beacons, or similar technologies to automatically record certain information from your device through which you use the website or avail our Services. This technical information may include your internet protocol (IP) address, device or browser type, Internet Service Provider (ISP), referring or exit pages, clickstream data, operating system, hardware model, operating system version, system log, network log, security log, performance logs, audit trails logs, event logs, unique device identifiers, usage information, user statistics and mobile network.
(ii) Device Access and Permissions: Subject to your explicit consent and device permissions, access to your device camera for document verification and KYC compliance, device microphone for voice-based authentication where applicable, your device’s biometric features, such as fingerprint or facial-recognition sensors, for secure login and transaction authentication, device information including storage capacity, device model, mobile network information, device type, IP address, precise and/or coarse location data, and device unique identifiers for various purposes in relation to onboarding on the Platform, KYC verification, fraud prevention, security and compliance requirements.
(iii) Geological Information: Such as precise or approximate location determined from your intellectual property (IP) address, mobile or other device’s GPS, or other information you share with us, depending on your device settings. We may also collect this information when you are not using our website and / or application if you enable this through your settings or device permissions.
(iv) Usage Data and Inferences: We may directly collect or generate certain information about your use of the Service (such as user activity data, analytics event data, viewing patterns of documents and clickstream data) for data analytics and machine learning, and to help us measure traffic and usage trends for the Service. We may also use third-party analytics tools that automatically collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Services.
3. Information we require for the providing the Services
This may include the (i) financial goals, (ii) demat account statements, (iii) details and transaction history from your savings, current, recurring deposit, and fixed deposit accounts, (iv) portfolio holdings, transaction records, and statements from your demat accounts, mutual funds, equities, and ETFs, and other securities, (v) insurance policies and related premium, claim or coverage information; (vi) credit information, credit scores or credit ratings issued by credit-information companies; (vii) details of real- estate assets and related documents; (viii) holdings in precious metals such as gold, silver and other similar commodities; (ix) information on crypto or other digital assets; (x) details of other non-traditional or alternative assets including art; (x) private investments in securities or otherwise; (xi) investment in and involvement with a start-ups; and (xi) other financial information, which may be collected only once you subscribe to the Services.
4. Information we receive from third-parties:
(i) Third-party platforms: If you use a third-party platform to register for or log into the Service, that site will provide us with some information to help you create or log in to your account. Furthermore, if you link your accounts with third parties to use our Services, we might use data from those accounts to enhance your user experience.
(ii) Data Through Account Aggregators: With your explicit consent, and solely for the purpose of providing our Services on Platform, we may receive financial information from your linked accounts via regulated account aggregators. This may include, but is not limited to:
(a) Bank Account Data: Details and transaction history from your savings, current, recurring deposit, and fixed deposit accounts.
(b) Investment Information: Portfolio holdings, stock holdings (including equity and preference shares) transaction records, and statements from your demat accounts; details of the investments in mutual funds and exchange-traded funds.
(c) Provident and Pension Fund Data: Balances and transactional information relating to your Public Provident Fund (PPF), Employees’ Provident Fund (EPF) and National Pension System (NPS) accounts.
(d) Insurance Data: Policy details, premium history and transaction history from your insurance providers.
(e) Other Financial Information: Any additional categories of financial information that may become available under the Reserve Bank of India’s Account Aggregator framework and for which you have separately consented, including, but not limited to, pension fund information or GST linked data.
(iii) Credit Information and User Uploaded Financial Data: With your explicit consent and separate authorization, we may collect and process:
5. Information through Cookies:
When you access the Service, we, along with our third-party partners, will send small text files (cookies) to your computer/system. These cookies uniquely identify your browser, enabling the Famli to facilitate faster logins, improve site navigation, remember preferences, and enhance overall user experience. They also provide insights into your usage patterns on the Services, allowing us and our partners to track your activity over time, measure traffic and trends, deliver personalized ads, and assess their effectiveness. You have the option to manage or reset your cookies through your web browser, customizing preferences and choosing to refuse or receive notifications about incoming cookies. Please note that disabling cookie acceptance may impact the functionality of certain features on the Service.
All of the above referred to as “Information”.
1. We use the Information for a variety of business purposes described below. We process the Information for these purposes, in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.
2. We use the Information which we collect or receive:
(i) To provide the Services: We may use the Information for providing Services to all users, including, without limitation in the following manner: (i) use the Information to conduct certain tests on open source programmes; (ii) analyse your financial position to provide effective investment advisory services; (iii) organize the data and content provided by you and facilitate usage of such content between team members; (iv) analyse your usage of the Services; (v) share Information with artificial intelligence platforms for the purpose of generating analysis and providing the Services, and, for the avoidance of doubt, your Information shall not be used by such artificial intelligence platforms for training their models, and shall be used solely for the provision of Services to you, subject to appropriate contractual safeguards and data minimization to ensure secure and limited use of your Information]; (vi) draft emails to share with potential targets and analyse emails to understand usage of the Services; (vii) studying your use of the Services to improve our services; (viii) communicate with our team and train our team; (ix) use the Information to provide Services to other users and share it with third parties in relation to provision of Services; (x) share Information with third party service providers, vendors, account aggregators, technology partners, and other business associates as required for the provision of Services and compliance with the applicable regulatory requirements; and (xi) other purposes ancillary to the Services provided by us.
(ii) For KYC Compliance and Regulatory Requirements: We may use the Information to conduct Know Your Customer (KYC) compliance processes as a mandatory prerequisite in accordance with SEBI guidelines and other applicable regulatory authorities for investment advisory services. This includes validation, verification, processing, and sharing of your KYC details, identity Information, nominee details, and beneficiary information with mutual fund houses, depository participants, account aggregators, or other service providers as may be required for compliance with applicable laws and for the provision of the Services through the Platform.
(iii) Risk Profiling and Suitability Assessment: We use the Information you provide to perform risk profiling and suitability assessments for investment advice. This Information includes the following: (i) age; (ii) investment objectives (including intended investment period and purpose); (iii) income details; (iv) existing investments/assets; (v) risk appetite/tolerance; and (vi) liabilities/borrowings. We assess both your willingness and ability to take risk by (a) evaluating your capacity to absorb loss, (b) identifying if you are unwilling or unable to accept potential loss of capital, and (c) appropriately interpreting your responses without attributing inappropriate weight to any single answer. Where we use questionnaires or other tools, we ensure they are fit for purpose and, that any limitations are identified and mitigated; all questions and descriptions are designed to be fair, clear and not misleading, avoiding vagueness, double negatives, complex language, and leading questions. We communicate your risk profile to you after the assessment and periodically update both the Information and the assessment to keep our advice appropriate
(a) To manage user accounts: We may use the Information for the purposes of managing your account and keeping it in working order.
(b) To request feedback: We may use the Information to request feedback and to contact you about your use of our Platform.
(c) To protect the Platform: We may use the Information as part of our efforts to keep our Platform safe and secure (for example, for fraud monitoring and prevention).
(d) To send administrative information to you: We may use the Information to send you product, administrative notices, alerts, advisories, and communications relevant to your use of the Services, including important notices regarding policy changes, terms and conditions updates, service modifications, and Platform administration.
(e) To post testimonials: If you authorize us to post testimonials about our Services, we may post your name and such other personal information that you permit us to post. We will provide you with an opportunity to review the testimonial before posting it on our website. If you wish to amend or delete the testimonial containing your personal data, you may reach out to support@famlilife.com .
(f) For other business purposes: We may use the Information for other business purposes, such as data analysis, customize the content and features of the Platform, request reviews of our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Platform, products, marketing and your experience.
(g) Anonymized Data: We may aggregate Information and analyse it in a manner to further accentuate the level of Services that we offer to our users. This Information includes average number of users of the Platform, the average clicks of the services, the features used, the response rate, etc. and other such statistics regarding groups or individuals.
(h) For legal requirements: To comply with legal and regulatory requirements or in connection with our contract. All of the above, “Purposes”.
All of the above, “Purposes”.
We may share the Information with the following persons for the following purposes:
1. External Partners and Service Providers: We may disclose the Information to third-party vendors, consultants, and service providers entrusted to carry out tasks or to aid Famli, including website analytics companies and artificial intelligence, for the purpose of providing Services. Transaction data is exclusively shared with our payment service providers to facilitate payments, process refunds, and address concerns or questions related to such transactions.
3. Revealing Information for National Security and Law Enforcement: We may need to reveal the Information in response to requests from public authorities, either due to our legitimate interest or legal obligation. There are instances where personal information may be disclosed without seeking your permission, including but not limited to the following reasons:
(a) Adherence to legal or regulatory obligations;
(b) Disclosure for reasons of national security; or
(c) Compliance with legitimate interests or legal obligations.
4. Disclosure to SEBI and its Intermediaries: You acknowledge that SEBI or other regulatory authorities may, at their discretion, inspect or call for client records, and we as an investment adviser may be required to disclose such information without prior notice. You further consent that, in the course of providing advisory services, the Investment Adviser may share client data with custodians, brokers, research analysts, technology service providers, or other regulated intermediaries, as may be necessary or required under applicable law.
5. Sharing with Affiliates: Subject to the applicable law, we may share the Information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we will control or that are or will be under common control with us.
6. Business Transfers: If Famli engages in any transaction that alters the business structure of Famli such as merger, acquisition, reorganization, or joint venture, we may process the Information for facilitating and concluding such transaction, and disclose the Information to the entity that acquires, or merges or engages in joint venture with Famli in which case the resultant entity will be bound by this Privacy Policy.
1. Cookies and Web Beacons
For Web-Based Access: We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Platform to help customize the Platform and improve your experience. Most browsers are set to accept cookies by default. You can remove or reject cookies but be aware that such action could affect the availability and functionality of the Platform. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis. Certain features may also rely on your browser settings or permissions related to cookies or local storage if you use our web application.
For Mobile Applications: For mobile applications on iOS and Android, we may use device identifiers, SDK-based analytics tools (such as Mixpanel or Firebase), and local device storage to monitor app usage, collect crash logs, and analyze engagement patterns. These technologies help us enhance your experience, monitor app performance, and offer personalized content. You may exercise control over or disable certain tracking mechanisms through your device settings, including but not limited to “Limit Ad Tracking” functionalities on iOS devices or “Opt out of Ads Personalization” settings on Android devices). Please note that disabling such settings may adversely
affect the performance or functionality of the Platform For more details or to manage your preferences, please refer to your browser or device privacy settings.
2. Website Analytics
We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Platform through the use of first party cookies and third- party cookies, to, among other things, analyse and track users’ use of the Platform, determine the popularity of certain content and better understand online activity.
2. Technical Security Measures: The Platform utilizes reliable and strong encryption mechanism such as TLS (Transport Layer Security, also referred to as SSL) certificates to secure transmission of your Information, particularly financial and payment data. We maintain secure hosting infrastructure with continuous monitoring, access controls, and authentication mechanisms to prevent unauthorized access and misuse of your Information.
3. Employee and Receiver’s Obligations: We have put in place procedures and technologies as per good industry practices and in accordance with the applicable laws, to maintain security of all personal data and information from the point of collection to the point of destruction. Our employees and third party who have access to your Information are bound by strict confidentiality obligations and contractual requirements to respect the privacy and security of your personal and financial data, however, this is carried out strictly on a need-to-know basis for provision of the Services. Any third-party receiving your Information must comply with our security procedures or maintain equivalent protective measures. However, we are not responsible for confidentiality breaches by partners and third parties outside the scope of our agreements with such entities.
4. User Security Responsibilities: You are responsible for maintaining the confidentiality of your login credentials, MPIN, OTP, and account access information. We do not undertake liability for unauthorized use of your account due to compromised credentials. You must immediately notify us at support@famlilife.com if you suspect any unauthorized access to your account and shall indemnify us for any losses arising from such unauthorized use.
5. Security Breach Notification: In case of any security breach affecting your Information, we shall make all legally required disclosures to you via email or Platform notification without unreasonable delay, consistent with law enforcement requirements and measures necessary to determine breach scope and safeguard data integrity.
6. You hereby acknowledge that Famli is not responsible for any information sent via the internet that has been intercepted beyond our control after having adopted reasonable security practices and procedures, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.
The links to third-party advertisements, third-party websites or any third-party electronic communication services or licensed payment platforms’ (referred to as “Third-Party Links”) may be provided on the Platform which are operated by third parties and are not controlled by, or affiliated to, or associated with Famli, unless expressly specified on the Platform. If you access any such Third-Party Links, we request you to review the concerned website’s privacy policy. We shall not be responsible for the policies or practices of such third parties.
We do not knowingly solicit data from children under 18 (eighteen) years of age. By using the Platform and Services, you represent that you are at least 18 (eighteen) or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Platform. If we learn that personal information from users less than 18 (eighteen) years of age has been collected, we will deactivate the Services and take reasonable measures to promptly delete such data from our records. If you become aware of any data that we may have collected from children under age 18 (eighteen), please contact us at support@famlilife.com and request the deletion of that child’s Information from our systems.
In case you request for deletion of your Information or cease to use our Services, we may retain such portion of Information for a period not exceeding 5 (five) years from the date user ceases to be associated with Famli or for such longer period as may be permitted/ required under applicable law and not with standing anything contained herein, including in, but not limited to, aggregated and / or anonymized form; or we may retain such data after account deletion for reasons including but not limited to the following purposes:
(i) if there is an unresolved issue relating to your account, or an unresolved claim or dispute;
(ii) if we are required to by applicable law; or
(iii) if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety
and security.
Subject to the applicable law, you have the following rights regarding your Information collected and
processed by us in connection with the Platform and Services:
1. Right of access: You have the right to access any Information that we process about you and to request:
(i) information about the categories of your personal data that we process and the processing activities we carry out on such data;
(ii) the identities of all other third party with whom we have shared your personal data (including the categories of personal data so shared); and
(iii) any other information relevant to your personal data as required under the applicable data protection law.
2. Right to rectification: If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the Information.
3. Right to deletion: You also have the right to request deletion of your Information, however, please note that in such case, Famli may not be able to provide the Services to you and such deletion will only be allowed when it is no longer necessary for the purposes for which it was collected or processed, subject to our legal and regulatory obligations to retain certain financial and compliance records under applicable laws.
4. Right to object and/or restrict: You have the right to object / restrict the processing of your Information by utilizing the opt-out mechanisms that we provide to you, in which case all or certain Services may not be available to you.
5. Right to redress your grievances: You have the right to redress your grievances by reaching out to our Grievance Officer (details are available below).
6. Right to withdraw your consent: If you do not agree with this Privacy Policy, you may refuse or withdraw your consent any time or alternatively choose to not provide us with any Information. Under such circumstance, we may be unable to render Services. An intimation to withdraw your consent can be sent support@famlilife.com . Such request for withdrawal of consent must be sent from the user’s registered email address.
7. Right to appoint a nominee: You have the right to appoint a nominee to exercise the rights on your behalf in the event of your death or incapacity to exercise your rights.
8. Right to Information and Grievance: You have the right to obtain information regarding whether your Information is transferred to third parties, or account aggregators, and the safeguards applicable to such transfers. You may also file complaints with appropriate supervisory authorities regarding our data processing practices.
9. If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request. This is to ensure that your data is protected and kept secure. We will handle your requests related to the exercise of your rights within 30 (thirty) days upon the receipt of your request. You may reach out to support@famlilife.com and/or compliances@famlilife.com the exercise of these rights.
When you register as a member or login to the Platform, authentication is completed through your registered mobile number using a one-time password (“OTP”) and/or the biometric credentials stored on your device; we do not presently require you to create a or maintain separate password for the Platform. You are solely responsible for securing your device, safeguarding access to your SIM card, and keeping each OTP confidential. You must not share OTPs or allow any third party to register their biometrics on your device if that device is used to access your account on the Platform. Any voluntary disclosure of an OTP or biometric access to a third party will be deemed authorised by you, and you will remain responsible for all activities and charges that may arise from such access. Any compromise of your device, SIM card or biometric credentials may result in loss of control over your account and personal information, as well as legally binding actions carried out on your behalf. If you believe your credentials or device has been compromised, you should immediately notify us, through the registered email address, at support@famlilife.com without delay if unauthorized use persists.
1. We only process your Information in compliance with this Privacy Policy and in accordance with the relevant data protection laws. If, however, you wish to raise a complaint regarding the processing of your Information or are unsatisfied with how we have handled your Information, you have the right to lodge a complaint with us at support@famlilife.com.
2. In case of any discrepancy or grievance with respect to all or any Information shared with Famli, please feel free to contact our Grievance Officer:
Attention: Jagminder Sehrawat;
Email ID: compliances@famlilife.com and
Address: 507, Orville Business Port, Viman Nagar, Pune, Maharashtra (411014)
3. We assure you that we shall ensure implementation of the Privacy Policy and shall make the Privacy Policy available to individuals and put our best efforts to redress the grievances of the user expeditiously within the timelines prescribed under applicable laws. The user agrees and acknowledges that Famli shall address and attempt to resolve the complaint received in accordance with the standard policies and procedures adopted by Famli.
4. Please feel free to reach out to us by e-mail support@famlilife.com in case of any concerns, grievances, or questions relating to our privacy or data related practices.
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