Privacy Policy

Last updated: Sep 18 2015

This Privacy Policy explains how altflo collects data and protects Personal Information (as defined below) and applies to current as well as former Users.

This Privacy Policy forms a part of, and has been incorporated, by reference, in the Terms of Use. Any capitalized terms that are not defined in this Privacy Policy have the meaning defined in the Terms of Use.

The term “Personal Information” refers to non-public information that personally relates to or identifies a User as an individual or an entity.

Each User, before providing, directly or indirectly through an agent, representative or intermediary, any Personal Information to altflo, is deemed to have carefully read and understood, and agrees to be bound by and comply with this Privacy Policy and the Terms of Use, each of which may be revised, modified, or replaced in its entirety, from time to time, without prior notice. Each User acknowledges and agrees to review the Terms of Use and this Privacy Policy each time, prior to accessing, or otherwise using, the Website, as each User will be deemed to have accepted any variations thereto if such User continues to use the Website after such variations have been posted on the Website. To the extent that any provision of this Privacy Policy is deemed to conflict with the Terms of Use, the Terms of Use shall have precedence.

Each User, by providing, directly or indirectly through an agent, representative or intermediary, any Personal Information to altflo, on or through the Website, or through any other means, gives us their express consent to collect and use their Personal Information as explained in this Privacy Policy. If any User objects to, or does not consent to, our use and/or disclosure of their Personal Information in accordance with this Privacy Policy, such User should not provide us such Personal Information (which may mean that such User will be unable to use some or all features of the Website).

This Privacy Policy shall not apply to any unsolicited information provided to us on or through the Website or through any other means. This includes, but is not limited to, information posted to any public areas of the Website. All such unsolicited information shall be deemed to be non-confidential and altflo shall be free to use or disclose such unsolicited information without limitation.

Each User, by submitting, or otherwise making available, directly or indirectly through an agent, representative or intermediary, any information, documents or material to altflo, on or through the Website, or through any other means, represents and warrants to have the authority, under applicable law or pursuant to any contractual or fiduciary relationships, to disclose all such information, documents or material, and is solely responsible for ensuring that each such disclosure is in compliance with all legal and contractual requirements, applicable to such User or to any information or material submitted or otherwise made available by such User, and strictly in accordance with this Privacy Policy and the Terms of Use

The Website is not directed toward minors. We do not intend to collect any personally identifiable information or any information otherwise from any person under the age of 18 years, or any person deemed a “minor” for the purposes of entering into agreements under the relevant and applicable jurisdiction.

The Website is controlled by us from India and accordingly, this Privacy Policy, and our collection, use and disclosure of your information, is governed by laws of India, and not by the laws of any country, territory or jurisdiction. We do not represent or warrant that the Website, or any functionality or feature thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to download, access or use the Website do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. By downloading, accessing, using or submitting any information to the Website, users from outside India acknowledge that the Website is subject to the laws of India, and consent to the transfer of their information to India and any other jurisdiction, which may provide a different level of data security than in their country of residence, and waive any claims that may arise under their own national laws.

What information do we collect?

To obtain an optimized user experience, you will be required to share your Personal Information at the time of registering with altflo, to help us verify your identity, to correspond with you, and to allow us to fulfill our legal and regulatory requirements. This information is used by us to verify and authenticate the Users, and is collected only on the basis of necessity. We also collect and maintain information about you in the course of your use of the Website.

We collect your Personal Information from the following sources:

  • Information you provide to us when you fill out account opening documents, complete a form, subscribe to our blog, or make a request for services, including, but not limited to, your full legal name, address, date of birth, e-mail ID and telephone number, relevant proof of identification such as copies of your PAN and passport, investment objectives, investment experience, assets and liabilities and/or income details and confidential documentation used to verify such information;
  • Information from your access or use of the Website; and
  • Other personally identifiable information about you that you may choose to disclose (including by authorizing any third parties to disclose) to altflo, its third-party service providers or business partners, including by completing profile forms, completing applications, questionnaires or similar documents, communicating with customer service personnel, and otherwise interacting with altflo, its third-party service providers or business partners.
  • altflo will not solicit the sharing of any Personal Information or any other private information from you through emails (other than emails originating from email addresses which end in "@altflo.co"), phone calls, or through any like medium other than the Website, or by means previously not disclosed.

If you submit any Personal Information of or relating to any other person or entity to us, our third-party service providers or business partners in connection with the Website, you represent that you have the authority to do so and that such submission is compliance with all legal and contractual requirements applicable to you and is strictly in accordance with this Privacy Policy and the Terms of Use, and you permit us to use and disclose such information in accordance with this Privacy Policy.

What do we use your information for?

Any of the information we collect from you may be used in one of the following ways:

  • To confirm your identity and vet any information (including any Private Information) provided by you, in order to ensure that you are eligible to use the Website and to protect you and us from fraud or other misconduct. We may also share such information about you with third parties, such as consumer reporting agencies and information verification services, to verify such information.
  • To correspond with you – altflo may need to send administrative information to you, including information regarding the Website and changes to our terms, conditions and policies, including, but not limited to, the Terms of Use and this Privacy Policy, and may require your Personal Information to allow you to send and receive messages and invitations to and from other individuals, through or in connection with the Website, and to send and receive such messages and invitations on your behalf. altflo will also use your Personal Information to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To enable transactions – to the extent that you upload Personal Information or execute any documentation via the Website (or any other means enabled by altflo) in connection with any transaction that you enter into, privately with any other User or any other person, we may share your Personal Information and such documentation to such Users or such other persons, which sharing would be communicated to you, through relevant messages on the Website and/or through any other medium, including, but not limited to, emails, phone calls, or text messages from us.
  • To improve our product and services – altflo understands that the needs of the Users constantly change to adapt to a dynamic realities. In order to gain meaningful insights into your needs and preferences, altflo may use Personal Information provided by you at the time of signing up and otherwise from time to time during your participation with us with the aim of constantly bettering our products and services, and achieving our goal of enabling transactions in alternative assets.
  • We might post on the Website, or otherwise use, your testimonials for the Website and/or altflo and these could include your name, location, organization and other Personal Information. We will obtain your permission prior to using such testimonials.

In order to protect against the loss, unauthorized access, misuse or alteration of the information entrusted to, shared with, or disseminated by us, we take generally accepted and industry standard security measures, both during the transmission and storage of such information. When you enter private, personal or confidential information on our registration forms or other forms specific to your needs, we encrypt such information using secure socket layer technology (SSL). All sensitive information such as User passwords are encrypted when stored on our servers.

We are committed to keeping your information secure and using it appropriately. We have adopted this Privacy Policy to ensure that your Personal Information is handled safely and responsibly, and we will strive to unfailingly:

  • Respect your trust and the confidential nature of the Personal Information you provide through your relationship with us;
  • Limit the collection and use of your Personal Information to that which we believe is necessary to serve you, administer our business or tell you about our services;
  • Restrict employee access to your Personal Information to those members of our team who need access to such information in order to provide you with services related to the transactions you are entering into through the Website;
  • Continually educate the members of our team to constantly reinforce the importance of confidentiality and client privacy;
  • Maintain appropriate physical, electronic and procedural safeguards and controls, including encryption technologies, designed to protect your Personal Information, in line with industry standards and practices; and
  • Quickly respond to your request to correct any inaccurate information.

We have invested our resources in the use of software, systems and procedures aimed at offering you a safe and secure transaction environment and protect your Personal Information. We plan to constantly review, refine and upgrade our security technology as new tools become available.

However, please be aware that no security measures are perfect or impenetrable. In unforeseen circumstances of technical failures or malfunctions, we will not be responsible to any user for any damage or loss resulting from it. We are not responsible for third-party circumvention of any privacy settings or security measures on the Website. In such cases we cannot guarantee that only authorized persons will view your Personal Information, and we cannot ensure that information you share on the Website will not become publicly available, unless such breach of security has been caused as a direct result of our gross negligence or wilful default. You can reduce some of these risks by using common sense security practices such as choosing a strong password and using up-to-date antivirus software. Your user identification and password are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them. We do not store or exercise any control over your user identification and password details, and bear no responsibility for the safekeeping of the same.

Please also be informed that we may use third-party service providers that provide hosting, data storage data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing, information and identity verification, background checks, credit checks, payment processing and other services pursuant to standard terms and conditions that are generally non-negotiable; accordingly, although we seek to conduct reasonable due diligence on such service providers, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Personal Information. We are not responsible for the data security measures of any third parties.

If you have any questions about security of the Website, you may contact us to find out more about the security measures we have implemented.

Do we use cookies?

Yes. “Cookies” are a feature of a web browser that allows web servers to recognize the computer used to access a site. They are small pieces of data that are stored by a user’s web browser on the user’s hard drive. Information gathered through cookies and web server logs may include information such as the date and time of visits, the pages viewed, time spent at a particular website, and the websites visited just before and just after such website. Cookies can remember what information a user accesses on one web page to simplify subsequent interactions with that site by the same user or to use the information to streamline the user’s transactions on related web pages. This makes it easier for a user to move from web page to web page and to seamlessly complete commercial transactions over the Internet. Cookies should make your online experience easier and more personalized. Cookies are only read by the server that placed them, and are unable to execute any code or virus.

We use site browser software tools such as cookies and web server logs to gather information about Users’ browsing activities, and gain insights into trends and statistics in order to improve the Website and better serve the Users. This information helps us to design and arrange the Website in the most user-friendly manner and to continually improve the Website to better meet the needs of current and prospective Users. We do not link cookies to personally identifiable information, and all information gathered through cookies is gathered in a manner so as to preserve the anonymity of its source, and is kept strictly confidential. The information is used and analyzed only at an aggregate level and none of such information is reviewed at an individual level.

Nevertheless, you can constantly control how and whether cookies would be accepted by your web browser; if you do not want your transaction details to be used in such manner, you can either disable your cookies or opt-out at the relevant download or request page. For more information on how to do so, please refer to the documentation accompanying your browser. However, if you have turned off cookies, many features of the Website may not be available to you.

Importance of Accurate Information

The most important factor for having an optimal experience with altflo is that all information, documents or other material we have about you are true, accurate and complete (nothing material has been omitted and nothing intentionally misleading has been provided). Our services primarily rely on User preferences that are submitted, which play a key role in accurately and efficiently mapping a User to such information as may be relevant to such User, and help us ensure that content on the Website is presented in the most effective manner based upon your interests. User preferences and information such as investment objectives and investment profile are also used to share information with unaffiliated third parties. Therefore, if your information changes, we urge you to update your information on the Website, and if you ever discover inaccuracies in our data, we request and encourage you to notify us immediately.

Do we disclose any information to outside parties?

Your right to privacy, and the confidentiality of your Personal Information, are of paramount importance to us. Any information provided by you will not be shared with any third party, except for the intended purpose for which such information is provided by you, in which case your consent would be implied. To the extent that you upload Personal Information or execute documentation via the Website (or any other means enabled by altflo) in connection with any transaction that you enter into, privately with any other User or any other person, we may share your Personal Information and such documentation to such Users or such other persons, which sharing would be communicated to you, through relevant messages on the Website and/or through any other medium, including, but not limited to, emails, phone calls, or text messages from us. Where consented to by you, we will share your Personal Information with other Users only to the extent necessary to enable such Users to explore potential relationships – the information shared would also include customary details, including, but not limited to, valuation multiples, profit margins, transaction structures, key drivers, challenges, etc. on a ‘no name’ basis. This information will generally not be used with, or intended to to disclose, your individual identification as a specific User or as a specific business represented by you.

We may share information with our affiliates, partners, and other persons with whom we have arrangements to service our Users if such information is required to provide the services you request. Further, we may use third-party service providers that provide hosting, data storage data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing, information and identity verification, background checks, credit checks, payment processing and other services pursuant to standard terms and conditions that are generally non-negotiable; accordingly, although we seek to conduct reasonable due diligence on such service providers, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Personal Information.

Without prejudice to the generality of the foregoing, we may authorize certain third parties, including, but not limited to, Mixpanel and Google Analytics, to track usage and collect information about Users and their activities on Website.

We do not however rent, sell, or share Personal Information about you with other persons for their direct marketing purposes.

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.

We reserve the right to disclose Personal Information when required by law, to regulatory, law enforcement, or government authorities. We may disclose your information (including Personal Information) as necessary to credit reporting or collection agencies for the purposes of fraud protection and credit risk reduction, or when necessary to protect our rights or property.

Third party links

Occasionally, at our discretion, we may include or offer third-party products or services on the Website. These third-party sites have separate and independent privacy policies, and you are advised to peruse the policies regarding privacy and related topics posted by such third-party sites before use. We are not responsible for third-party content accessible through the Website, including opinions, advice, statements and advertisements, and you shall bear all risks associated with the use of such content. We are not responsible for any loss or damage of any sort which you may incur from dealing with any third party.

Nonetheless, we seek to protect the integrity of the Website and welcome any feedback about these sites from the Users.

Applicability to past-Users

Should you delete your account with us, altflo will retain your information (including Personal Information) for regulatory compliance, internal record-keeping and other administrative and statistical purposes for a reasonable period or for as long required under applicable law. However, we would like to emphasize that we are just as committed to protecting the privacy of former Users as we are of current Users. If you choose to become an inactive User, your Personal Information will continue to be protected by the privacy policies and principles described in the version of this Privacy Policy in force and effect at the time.