This document is an electronic record in terms of the Information Technology Act, 2000 and the rules made thereunder.
This Privacy Policy describes how Gracia Global Advisory LLP, having its registered office at Office No. 102, 1st Floor, Rushabh CHS Ltd, Chaphekar Bandhu Marg, Near Khandoba Temple, Sane Guruji Nagar, Mumbai – 400081, Maharashtra, India (“Gracia”, “we”, “us” or “our”), processes personal data in connection with the FinBowl platform (“Platform”). By accessing or using the Platform, you acknowledge this Privacy Policy.
1.Role of the Parties
Organisations subscribing to the Platform (“Clients”) determine the purposes and means of processing personal data submitted to the Platform and act as the Data Fiduciary under the Digital Personal Data Protection Act, 2023.
Gracia processes such personal data solely on behalf of the Client for the purpose of providing the services and acts as a Data Processor, and engages Subprocessors (as described in paragraph 5.1) to assist it in doing so.
The Client is responsible for having a lawful basis and obtaining all consents required, including for verification of any individual through the Platform.
2.Data Processed
Gracia processes: (a) user account information; (b) data, documents and records submitted by Clients; (c) verification details, including PAN, GST, bank account, UPI, IFSC, Udyam and KYC details; (d) information required for email, SMS, WhatsApp OTP and in-app notifications; and (e) audit trails and activity logs.
3.Purpose of Processing
Personal data is processed solely to provide the services, perform verification workflows, host and secure data, administer user accounts and authentication, maintain audit trails and security logs, provide support, maintain the Platform, improve system reliability and comply with applicable law.
4.Restrictions
Gracia shall not sell, disclose or commercially exploit Client data, and shall not use Client data to train general purpose artificial intelligence models unless expressly agreed in writing.
5.Disclosure to Third Parties
Gracia engages third-party service providers, including verification, document processing and artificial intelligence infrastructure providers, as “Subprocessors”, who process personal data for the purpose of providing the services and are bound by written agreements to implement appropriate safeguards for the protection of personal data.
Gracia may disclose personal data where required by applicable law, court order or a governmental authority.
6.Security
Gracia maintains reasonable technical and organisational safeguards, including encryption, access controls, activity logging, backup and incident response procedures. Personnel with access to personal data are bound by confidentiality obligations.
Where required under applicable law, Gracia shall notify the affected Client of a personal data breach without delay upon becoming aware of it, and shall follow up with fuller particulars of the breach, including its likely impact and the remedial measures taken, as soon as reasonably practicable and in any event within seventy-two (72) hours of becoming so aware.
7.Retention and Deletion
Upon termination of a subscription, the Client may export its data within thirty (30) days. Gracia shall delete or render inaccessible Client data in production systems within ninety (90) days of termination, save where retention is required by law or for the establishment or defence of legal claims. Backup copies shall be deleted in accordance with Gracia’s standard retention schedules.
8.Requests From Individuals
Requests to access, correct or erase personal data should be directed to the Client that holds such data. Gracia shall reasonably assist the Client in responding to such requests.
9.Governing Law
This Privacy Policy shall be governed by the laws of India, including the Digital Personal Data Protection Act, 2023 and the Information Technology Act, 2000.
10.Amendments
Gracia may amend this Privacy Policy from time to time by posting the revised version on this page.
11.Contact
Gracia Global Advisory LLP, Office No. 102, 1st Floor, Rushabh CHS Ltd, Chaphekar Bandhu Marg, Near Khandoba Temple, Sane Guruji Nagar, Mumbai – 400081, Maharashtra, India. Email: support@finbowl.ai
Questions about this document?
Write to support@finbowl.ai or reach us at Gracia Global Advisory LLP, Office No. 102, 1st Floor, Rushabh CHS Ltd, Chaphekar Bandhu Marg, Near Khandoba Temple, Sane Guruji Nagar, Mumbai – 400081, Maharashtra, India.