Privacy Policy:
This Privacy Policy is published by Styflowne financial services pvt ltd , a company
incorporated under the Companies Act, 2013, having its registered office at Municipal No. #201,
First Floor, Smart Square Complex, 100 Feet Road, Indira Nagar 2nd Stage, Bangalore-560038
(CIN) U72900KA2021PTC151652 (hereinafter referred to as “Company” and/or “Styflowne” which
term, unless repugnant to the context or meaning thereof, shall mean and include its directors
employees and associates to provide the privacy policy that will be applicable in the context of
the Styflowne (hereinafter referred to as its "Application") and govern the persons downloading,
signing up/registering on the Application and purchasing the financial products as presented by
Advisor through the Application (hereinafter referred to as "End Customer" ) or downloading
signing up/registering and/or promoting financial products of Company’s clients products and
services on the Application to the End Customer (hereinafter referred to as "Advisor/s") (End
Customer and Advisor/s shall collectively be referred to as "Users").
This Privacy Policy is published in accordance with the relevant provisions of the Information
Technology Act, 2000 (hereinafter referred to as the “Act”), Information Technology (Reasonable
Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (hereinafter
referred to as the "IT rules") and the Information Technology (Intermediary Guidelines) Rules
2011 (hereinafter referred to as the "Intermediary Rules") and such other applicable laws.
Through this Privacy Policy, Company provides information about the details it collects from
Advisors (including but not limited to personal and sensitive information as described in the IT
rules) hereinafter referred to as "Information" (It is explicitly clarified that the
term "Information" shall mean and include the information described in clause 2 of this Privacy
Policy), the purpose of such collection, disclosure of data, the mode of removal or updati ng
Advisor Information, practices and safety measures and grievance redressal mechanisms in the
following manner:-
Company is engaged in the business of advertising the financial products on its Application
to the Advisors to enable them to promote the same to End-Customers. For more information
about the products please go through the Application.
Company collects the following Information from the Advisor for the following purposes:
a. Information collected and purpose it is collected for
o Name.
o Access to location – to enable the Advisor to use the Application.
o Biometric Access (face-scan, fingerprint scan) and screen lock to enable Advisor to access
the Application.
o mobile number registered on UPI payment system – for remitting payment of the
o WhatsApp permission for sending a notification, for sharing leads and product related
information, messages, invite links etc.
o Contacts - To enable advisor to add new End-Customers to the Application.
o Aadhar number - for KYC compliance.
o PAN number - for KYC compliance.
o Address as per Aadhar – for KYC compliance.
o Bank details – to remit the payment
o Paytm Mobile No. – to remit the payment
o Email ID - for communication purposes
o Camera - To enable the advisor to take pictures for the purposes of the Application
o Photo Gallery – To enable the advisor to upload a profile photo
o Educational Certificates – For verifying the advisor’s educational qualification for making them
an insurance agent.
o Point Of Sales License (IRDAI) – For verifying the POS license holder
o Such other ancillary details connected to the aforesaid.
Company collects the following information from the End Customer for the following
purposes:
o Mobile No. – To register end-customer details on the Application before they can proceed to
apply to the Products on the Application.
o PAN no. – For KYC compliance and to register end-customer details on the Application before
they can proceed to apply to the Products on the Application.
o Name as per Aadhaar Card – for KYC compliance and to register end-customer details on the
Application before they can proceed to apply to the Products on the Application.
o Email Address – for communication purposes to register end-customer details on the
Application before they can proceed to apply to the Products on the Application.
o Pin-code - To register end-customer details on the Application before they can proceed to
apply to the Products on the Application.
Purpose of collecting information
While the specific purposes are covered above, the generic statement of purpose is as
mentioned below:
o To enable Advisor and End Customer to use the Application
o To enable the Advisor to withdraw the amount from the bank.
o To facilitate the transactions or report on these transactions;
o To undertake research and analytics for offering or improving the products/services and their
security and service quality;
o To check and process Advisor’s requirements or instructions or requests received from End
Customers and/or Advisors in respect of the products.
o To share with Advisor, updates on changes to the products/services and their terms and
conditions including the Application’s terms and conditions.
o To verify identity and to provide products to the Advisor.
o To carry credit checks, screenings or due diligence checks as lawfully required by the
Company.
o To undertake financial/regulatory/management reporting, and create and maintain various risk
management models.
o To conduct audits and for record-keeping purposes.
o To comply with the requirements of applicable laws/regulations and/or court orders/regulatory
directives.
o To allow Advisors to sign-up or set-up their account with Company.
o To initiate legal action in case of breach by Advisor .
o The Information is collected for Company to understand the kind of Advisor and End
Customers accessing Company Application.
o The Information is collected for Company to understand the Advisor and End Customer
behaviour and to customize or modify or enhance its services accordingly.
o The information is collected for the End Customers to explore and apply for Products listed on
the Application.
Company neither rent’s nor sell’s User personal information in personally identifiable form to
anyone. Company shares User’s personal information in personally identifiable form with
third parties only as described in this Privacy Policy. The Information is stored by Company
(including by its associates/employees and auditors/attorneys hereinafter referred to as
“Authorised Personnel” and third party software enabled on the Application in its electronic
and physical databases. However, it is hereby clarified that:
o Reasonable safety practices as per Indian standards are enabled on the Application (and the
Company Application is encrypted), the electronic and physical databases to protect the data
collected by Company and to prevent unauthorized access to third parties.
o The Authorised Personnel will be provided access to the data only on a need to know basis
and with an obligation cast on them to protect the confidentiality of such data.
o The Information will be used for the purposes described in clause 2 of this Privacy Policy.
o Company will not share User personal information with third parties without User permission
unless Company’s ownership changes or Company merge’s or enters into a joint-venture
with another party; or Company is required to do so under any law, or in connection with any
legal proceedings and/or to defend our legal rights.
o Company does not knowingly collect personal and sensitive information from persons aged
below 18 years.
In case Advisor wishes to obtain a copy of their personal information or wants to delete or
update their personal information or withdraw their consent to publish their Information or if
the Advisor has any grievance pertaining to the Company’s Application then such person can
contact Company’s grievance officer Mr. Soumitra Bhadra by sending an email or mobile
no regarding their request to soumitra@Styflowne.com (+91-81500-25844) with the subject
line as "Acceleration of grievance". Upon satisfactorily ascertaining the credentials of the
person seeking the information, Company shall with the Advisor’s cooperation, assist them in
redressing the grievance or request in a timebound manner. Further, it is clarified that in the
event the Advisor withdraws their consent to publish their Information or makes a request of
above-mentioned nature in the manner specified above, Company shall at its sole discretion
have the rights to disable or restrict or block such Advisor’s registration or access to the
Application.
Company may use third-party advertising companies to serve ads when the User visit the
Application or Company shall post third-party financial products on the Application. When the
Advisor or End-User applies for such products the End-Customer may be redirected to the
said third-party webpage or application. These companies and third-parties may use
information (including but not limited to) the User’s name, address, email address, telephone
number, or sensitive personal information) about User’s visit to the Application in order to
provide advertisements about the products and services of interest to User. Further, such
advertisements may have hyperlinks that lead to the advertiser’s or third-party’s website.
COMPANY HEREBY EXPRESSLY CLARIFIES THAT COMPANY IS NOT MAKING ANY
WARRANTIES AND SHALL UNDER NO CIRCUMSTANCES BE RESPONSIBLE FOR THE
PRIVACY SAFEGUARDS OF SUCH WEBSITES OR APPLICATIONS OR THE ACCURACY
OR AUTHENTICITY OF THE DATA CONTAINED IN SUCH WEBSITES OR THE
ADVERTISEMENTS, USERS ARE ADVISED TO REFER TO THE PRIVACY POLICIES
AND TERMS OF USE OF SUCH WEBSITES AND EXERCISE REASONABLE CAUTION
AND DILIGENCE WHEN USING SUCH THIRD PARTY WEBSITES.
IT IS HEREBY CLARIFIED THAT THE ACCEPTANCE TO THIS PRIVACY POLICY AND
THE TERMS OF USE IS A PRECONDITION FOR THE USER TO VISIT OR USE THE
APPLICATION. IN THE EVENT, THE USER DISAGREES TO PROVIDE SUCH
ACCEPTANCE THEN SUCH USERIS REQUIRED TO LEAVE/STOP VISITING OR USING
THE APPLICATION IMMEDIATELY. THE USER’S ACT OF USING OR VISITING THE
APPLICATION SHALL BE DEEMED AS ACCEPTANCE BY THE USER TO THE PRIVACY
POLICY AND TERMS OF USE.
Company reserves the right to update or modify all or any part of this Privacy Policy and
such update or modification shall (unless specified otherwise) be effective from the date the
same is published on the Application. However, Users are encouraged and advised to visit
the Privacy Policy section from time to time to ascertain if any update or modification has
been made to the same.
While Company has taken appropriate steps for the security and protection of Application,
however, Company shall not be responsible for any breach of security or the disclosure of
personal data for reasons outside its control, such as hacking, social engineering, cyber
terrorism, espionage by third parties, or any events by way of force majeure such as
sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of
any kind, riots, insurrection, war or acts of government.
