GENERAL

We are committed to keeping your data secure, your private information private, and being transparent about our practices. We adhere to the best practices to secure information collected from You & stored on behalf of You.

At Kuttl, we prioritise privacy and security in all our operations. This Privacy Policy explains how Kuttl, provided by MONOIDLABS PRIVATE LIMITED and its subsidiaries (collectively referred to as “Kuttl,” “we,” “our,” or “us” or “Company”), processes the information we collect through our websites, mobile apps, and other online services (collectively, the “Services”), and during your interactions with us, such as through our customer care service channels. The Company owns, operates, and manages the website https://www.kuttl.in and the related software application, designed for use on wireless devices like smartphones and tablets, as well as on desktop and laptop computers, under the brand name “Kuttl” (collectively referred to as the “app” or “Application”).

The app facilitates and enables the User in availing certain online products and services from the app, including, inter alia, varied e-commerce related services to the Users (“Services”), in accordance with the terms and conditions of use/Service of the app, as available at https://www.kuttl.com/privacy-policy (“Terms and Conditions ”).

For the purposes of this privacy policy (hereinafter referred to as "Privacy Policy" or "Policy"), wherever the context so requires, references to the terms "User(s)", "You" or "Your", shall mean and include the user, registered on the app, who uses or access the app or avails the Service(s) (as defined below) of the app in accordance with the Terms of Use.

This Privacy Policy is published in compliance with the Information Technology Act, 2000, and applicable amendments, rules, regulations and guidelines enacted thereunder from time to time (“IT Act”) with specific mention of regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive personal information) Rules, 2011, and any other national and state laws which relate the processing of data. This Privacy Policy is an electronic record in terms of the IT Act and this electronic record is generated by a computer system and does not require any physical or digital signatures. Any new features and/or services that are added to Our current service at any point in the future shall also be subject to the terms set out in this Policy along with any other future relevant legislations to be incorporated as per the laws of the land. This Privacy Policy shall apply to any person who visits, browses, uses or accesses the app or use any Services on the app.

This Privacy Policy, inter alia, states: (i) the type of information collected from the Users, including personal information and sensitive personal data or information (as defined below), relating to an individual; (ii) the purpose, means and modes of collection, usage, processing, retention and destruction of such information; (iii) how and to whom We will disclose such information; and (iv) how We will protect the Users’ personal information when they access the app.

Kuttl does not knowingly collect or solicit personal information from individuals under the age of 18. If you are under 18, please refrain from registering for the Services or providing any personal information about yourself to Kuttl. In the event that Kuttl becomes aware of having collected personal information from a person under the age of 18, we will take steps to remove that information promptly. If you suspect that someone under 18 has provided us with their personal information, please reach out to us at Company@kuttl.in for assistance.

 

PURPOSE AND SCOPE OF PRIVACY POLICY

This Privacy Policy is designed to inform and explain to our users the guidelines and procedures we follow in handling the information we receive from users on our app. This includes information collection, storage, processing, and sharing, as part of our services or during transactions on the app. Our policy aims to familiarize you with our practices, emphasizing our dedication to protecting your privacy and personal information. The terms "using" and "processing" information in this policy cover activities such as using cookies, authentication and managing, modifying, and handling your information in various ways.

The below mentions the outlined idea of Scope of the Privacy Policy:

• This Privacy Policy applies to all users of Kuttl's app. When you use our services, register, or provide us with your information, it is considered that you have read, understood, and agreed to the practices and policies detailed in this Privacy Policy. You are also agreeing to adhere to the terms set forth in this document.

• At Kuttl, we understand the importance of knowing how and why your information is collected, used, disclosed, transferred, and stored. Our Privacy Policy clearly outlines our procedures for processing your information in alignment with relevant data protection laws when you visit our app or use our Services. By accessing Kuttl's app or using our Services, you acknowledge and agree to comply with the terms of this Policy.

• It's essential for you to thoroughly read this Policy along with any other policies we may issue at times when we're collecting or processing your personal information. This ensures you are fully informed about how and why Kuttl is using your personal data.

• This Privacy Policy is specific to information provided through the Kuttl app. We may periodically update this policy to reflect changes in our Services. Any amendments will be made directly to the Privacy Policy on the app, and these changes will become effective immediately upon posting. Additionally, we will inform all our users about any significant changes through email or another specified communication method.

• The Kuttl app securely stores all information and user data on a server that adheres to top security practices as assured by the server service provider. Being an India-based app, Kuttl is committed to complying with all applicable Indian laws, regulations, rules, and notifications that govern privacy and data protection.

• This Privacy Policy does not apply to any third-party website(s) and mobile app(s). You are requested to take note that information and privacy practices of Our business partners, advertisers, sponsors or other sites to which We provide hyperlink(s), may be different from this Policy, Hence, it is recommended that You review the Privacy Policy of any such third parties before You interact with such interfaces. Under such circumstances we kindly recommend you to read the policies on the applicable / relevant websites or sources.

You hereby consent to Us collecting, using and sharing and disclosing Your information as described in this Privacy Policy. We stand true to our users and keep Your data safely and securely. We also DO NOT share/sell your data to any third parties without your consent. Therefore, in any unforeseen scenario, if You do not agree with this Privacy Policy or feel your data is being risked, please restrict use any of the services or access the app or give Us any of Your information and do let us know promptly of the issues and we would resolve the same at the earliest. 

 

COLLECTION OF PERSONAL DATA

To access features and services on the Kuttl app, users may need to provide personal or sensitive data. This information is protected under Regulation 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.

We may collect the following categories of personal information or sensitive personal data or information from the User but not limited to:

ON BOARDING / REGISTRATION OF SERVICES:

When You create a new account to use the Services we request for the following information:

• Name, DOB, Gender, Country(for data localisation & governance)

• phone number

•  Information in relation to Your device while using our app (on basis of Your consent) like communication information including device information (including storage, model, mobile network information, device type, IP Address and location, device unique identifier) which might be necessary for location based services, KYC requirement, fraud prevention, security and compliance requirement, technical and operational usage etc.

• Browser plug-ins, and cookies, tokens or similar technologies that may identify your browser Application and plug-ins, notifications etc.

• Address details for Billing Purpose of Kuttl App subscription only. 

*We understand the sensitivity of your data and have strict data privacy laws to safeguard user’s private information.

YOUR PURCHASE RELATED INFORMATION LIKE ORDER DETAILS, TRACKING DETAILS ETC. VIA SMS (SHORT MESSAGE SERVICE) ON YOUR ANDROID PHONE (APPLICABLE FOR ONLY ANDROID PHONES):

• You have the option to grant explicit consent for Kuttl's Android App to access your SMS inbox on your Android mobile device.

• Upon your consent, the Kuttl Android App can automatically read SMS text messages related to financial transactions from various providers, including but not limited to banks, retail outlets, businesses and financial institutions.

• This enables Kuttl to consolidate and analyze your transaction data and savings account balances, offering a comprehensive view of your financial status and wealth on the app dashboard.

• Kuttl assures that no personal messages or OTPs will be accessed.

• You can withdraw consent for these analytics services at any time by contacting support@kuttl.in or through the app’s settings

PURCHASE INFORMATION:

We provide option for you to update your investment information in a secure manner: Upload your purchase invoices in PDF for it to be processed, for which updates are not received on E-mail or SMS. 

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GOOGLE ACCOUNT EMAILS (GMAIL):

The User may also choose to provide explicit consent to connect/integrate the User’s Gmail account(s) with his/her account on the app. You can also choose to integrate Your one or more of email accounts by connecting such account(s) with Your account on the app. The following are the information collected from Your consented email accounts:

• The attachments from the senders who have the details of your purchases/subscriptions such as tracking details, order updates, payment methods like your credit card, statements, spends. Kuttl organises this information in your account to provide deep analytics and other services.

• We access your Gmail account, only basis your explicit consent for auto tracking your purchases & spends in order to effectively help you in organising your post purchase journey. We will only be accessing and analysing the contents of emails (including the attachments) consisting of ‘read-only’ in a secured manner. You can choose to grant your explicit consent to connect your Gmail account with Kuttl account (using Google’s OAuth authentication method).

• The benefit of opting to connect Your Gmail account is that your both investment and expense information gets updated automatically every month. Given the updated information, the application can hence give you deep and accurate analytics on your net worth and to curate best offers for you to avail various products / services via our app.

• You can anytime choose to de-link your Gmail account with the application at any time and/ or you can delete your information by writing to company@kuttl.in.

• Please note that such data obtained by this integration will be used by the Company solely for providing the Services and for improving the User experience pertaining to the features of the App.

• We proactively encourage the User to review the information prior to giving consent for integration of the email address with the account on the app. The User may at any time opt to de-link the email address connected with the account opened on the app and/or delete the information by writing to company@kuttl.in.

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PROCESSING OF PERSONAL INFORMATION

We may process your personal information collected from You for, including without limitation, the following purposes:

Services opted in app (Purchase Tracking, AI insights, recommendations, etc):

• To accommodate your requests regarding Kuttl's diverse range of services, we process the stored personal information to consolidate your purchase data in one place on our app. This enables Kuttl to offer analytics on your purchases and alerts, assist in managing pending and missed refunds, and provide insights into your spending patterns. Our goal is to help you make informed decisions about your purchases, utilizing our app's features for organization and smart purchase tracking.

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Payment method communications:

• App will automatically access  & sync the contents of your purchase-related emails continuously for managing your complete purchase information including your payment methods like credit cards, UPI etc. This includes organising and highlighting purchase details, reminders for pending actions, analysis of spending patterns. This process is designed to provide a comprehensive and user-friendly overview of your purchases and related activities.

Alerts/ notices:

• To keep you informed and enhance your experience with our service, we will send you administrative notices, alerts, and communications relevant to your use of Kuttl. This includes important updates about our services, changes to terms and conditions, and policy updates. These communications are essential for the effective administration of our business and app, ensuring you are always up-to-date with the latest information and developments related to our services.

Customisation of app/ offers:

• To enhance your experience on our app, we will customise content and may request your reviews of our services. Verification messages or emails may be sent to validate your account and prevent misuse or abuse. 

Compliance with applicable laws:

• to deal with enquiries and complaints raised by You and to troubleshoot problems, ensure compliance with all applicable laws and to ensure safety of the app and all Users, to prevent fraud, errors and/or any illegal activity on the app, for conducting audits and for record keeping purposes

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DISCLOSURE OF DATA

We may need to disclose your personal information in response to legal processes, requests from public or governmental authorities, or as required by law, either within or outside your country of residence. Additionally, if we deem it necessary for law enforcement, national security, or to prevent activities we consider illegal, unethical, or legally actionable, we may also disclose your personal information.

• Our app features sections that are accessible to all users and visitors without registration, as well as sections that require user details, username, and password for access. To ensure the security of your username, password, and other information, we advise using a safe and secure server when accessing these sections of the app.

• We do not guarantee the security or privacy of information made publicly available by users and visitors on our app. Additionally, the app may contain links to third-party websites. We do not endorse these links or websites and are not responsible for the privacy practices of such external sites.

• We automatically collect the URL of the site from which a visitor arrives, along with the Internet Protocol (IP) address, operating system, web browser type, email patterns, and the name of the Internet Service Provider (ISP). This data helps us analyse trends to improve our services. The connection between a user's IP address and personal identification is not disclosed to third parties. However, we may share anonymized, aggregate findings with partners to support our business growth

• Please note that We maintain a strict no-spam policy and do not rent, sell, disclose or share personal information belonging to You with other people or non-affiliated companies without Your consent, except to provide you the Services which You have requested for or otherwise as specifically provided for in this Policy.

You agree that in addition to as may be provided in this Policy, We may also disclose Your personal information under the following circumstances:

Third party service professionals and/or providers:We collaborate with third-party service professionals/providers for various app-related services, under confidentiality agreements and in accordance with law. These providers may use your personal information to assist us in communicating offers, service feedback, payment processing, customer support, and advertising. Services may include payment processing, maintenance, fraud detection, database management, web analytics, and delivery/logistics. In such cases, your information may be shared with these third parties to facilitate or improve our services;

Compliance with laws and protection of UsersWe may release your personal information to comply with legal requirements, respond to court orders, judgments, decrees, injunctions, arbitral awards, administrative orders, or governmental investigations. This is also applicable in cases where we need to establish or exercise our legal rights, defend against legal claims, or when we believe it's necessary to protect your or others' rights and property. Additionally, sharing your information might be required for enforcing and complying with our terms of service and company policies;

Business transfer and mergers:We may transfer Your personal information if the Company, is acquired by or merged with another Company, to the extent permitted by applicable law and/or required under the scheme/arrangement of merger, etc. In such an event We will notify You before Your personal information is transferred/shared with the other entity and hence becomes subject to a different Privacy Policy;

Contracting parties: We transfer/share Your information with Our service professionals, group companies or business partners to facilitate the availing/provision of Services by You.

With Your consent in addition to the aforementioned circumstances, We may share Your personal information with third parties with Your prior consent and/or at Your request if necessary at future course of time.

 

COLLECTION AND USE OF NON-PERSONAL DATA

We collect non-personal data such as customer activities on our app for research, analysis, and service improvement. This aggregated data, which cannot identify individuals, may be shared with third parties to enhance customer experience and services. Our app uses cookies, and users are prompted to accept them. Cookies are text files placed in your computer's browser files to improve your experience on our app.

 

COOKIES POLICY

Cookies on our app do not contain personal information unless you have provided it. They are used to associate your usage and behavior on the app with the information you have willingly supplied. A cookie can hold only the data you provide and cannot access data on your hard disk or read cookie files from other websites.

We use both permanent and session cookies on our app. Permanent cookies stay in your browser until they expire or are deleted, while session cookies are deleted at the end of your browsing session. You can disable cookies in your browser settings or set your browser to alert you before accepting them. Declining our cookies may affect your use of the app, especially post-login. Temporary cookies can be cleared by quitting the browser; however, for assurance, users should manually clear their cookies. Your status as a casual visitor changes if you've submitted personal information, making you a user under this Privacy Policy. Third parties process cookie data to improve or facilitate our services, including maintenance, fraud detection, and web analytics. For any inquiries about our cookie policy, please contact us using the provided details.

 

YOUR RIGHTS AND HOW TO EXERCISE THEM

We honor your rights regarding your personal data. You can request access to, or a copy of, your personal information held by us. You're also entitled to correct, delete, or restrict the processing of your data. Users can change email and contact preferences anytime through their account settings on the app. You have data portability rights. If you object to how we use your data under this Policy, please contact our privacy team. Verification may be required to prevent misuse.

 

DISCLAIMER OF INFORMATION

We are not liable for your interactions with other users, third-party providers, or their products and services. By using our services, you waive any claims against us related to these interactions, and in cases where a waiver is not effective, you agree to release us from such claims.

You are responsible for ensuring the accuracy and completeness of information you submit on the app. You agree to indemnify us against claims arising from incorrect information you provide. You can update your information on our member page or contact us. However, we may not change information in certain cases, like evaluative opinion data or documents related to ongoing prosecutions. To cancel your account or stop using your information for services, contact us using the provided details.

 

SECURITY

We understand the serious implications of data security and take extensive measures to ensure Your data and information is secured. We take extensive technical and legal measures to safeguard Your personal data and information.

• The app uses a reliable SSL certificate to ensure Your personal data and information is not misused in any manner whatsoever. We use SSL encryption when transmitting certain kinds of information, such as financial services information or payment information.

• Our employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every User’s personal information or sensitive personal data and information.

• We have put in place procedures and technologies as per 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. Any third-party data processor to which We transfer personal data and information shall have to agree to comply with those procedures and policies or put in place adequate measures on their own.

• No administrator of the app will have knowledge of Your OTP. It is important for You to protect against any unauthorised access to Your OTP, Your contact details and Your mobile phone. Ensure You log off from the app when finished. We do not undertake any liability for any unauthorised use of Your account.

• If you suspect unauthorised use of your account, immediately notify us at company@kuttl.in. You're responsible for losses due to unauthorised account use. 

• In case there is any breach of security, We will make all legally required disclosures concerning the breach and the confidentiality, or integrity of Your unencrypted electronically stored "personal information" to You via email or By posting it on app without any unreasonable delay, in as far as is consistent with any legitimate needs of law enforcement and any measures required to determine the scope of the breach and to safeguard the integrity of data.

• We at Kuttl are committed about our user's data and privacy. We blend security at multiple steps within our products with state-of-the-art technology to ensure our systems maintain strong security measures.

 

COMPLIANCES

We are in process to get ISO 27001:2013 certification for our company and have implemented required Information Systems Management System policies and procedures in order to maintain industry standard best practices and applicable controls as necessary for protecting the data of Our Users.

Kuttl's use of information received from Google APIs will adhere to Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes), including the requirements as necessary to the extent of adhering to the scope and policy.

We will also be undergoing annual security assessment from a Google-designated third party and keep the same updated from time to time or as per instructions from Google and will publish the “letter of assessment” on Kuttl website and mobile applications.

 

DATA STORAGE AND RETENTION PERIOD

We do not keep your personal data and information longer than necessary for the purpose of the processing except for any record retention required by applicable laws, including but not limited to Securities and Exchange Board of India (Investment Advisers) Regulations 2013, Insurance Regulatory Development Authority of India (Registration of Corporate Agents) Regulations 2015 and Prevention of Money Laundering Act 2002. This includes, for example, the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to carry out legal work, for the establishment or defence of legal claims. We may aggregate and anonymize your personal data and information (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

 

CHANGES IN PRIVACY POLICY

We reserve the right to modify this Policy at any time. Changes are effective immediately upon posting on our site. While we endeavour to notify you of updates, we recommend regularly reviewing the policy. If you disagree with any changes, you may discontinue using Kuttl's services. To update or delete your personal information, or for any discomfort with the changes, email us at company@kuttl.in.

 

QUESTIONS OR COMPLAINTS

If you have any questions or concerns about how your personal information is processed, please reach out to us at company@kuttl.in. Our team is ready to assist you with any inquiries or issues you may have.

 

CONTACT INFORMATION

For any inquiries or support related to Kuttl, please contact us at our registered address: #1207/343 & 1207/1/343/1, 9th MAIN, 7th SECTOR, HSR LAYOUT, BANGALORE, KARNATAKA 560102. For direct communication, you can email us at company@kuttl.in.

 

GRIEVANCE OFFICER

In accordance with the provisions of the Information Technology Act, 2000, and rules made thereunder, the name and contact details of the Grievance Officer are provided below:

Attn: Mr. Varunesh Kumar

Designation: Grievance Officer

Email: varunesh@kuttl.in

Time: Mon - Friday (10 AM - 7 PM)

Address: #1207/343 & 1207/1/343/1, 9th MAIN, 7th SECTOR, HSR LAYOUT, BANGALORE, KARNATAKA 560102. For direct communication, you can email us at company@kuttl.in