Privacy Policy

This document is an electronic record in terms of the Information Technology Act, 2000 and rules made thereunder. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This document is published in accordance with the Information Technology Act, 2000 read with Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.

1. Tutelar Fintech Private limited ('Tutelar', 'we', 'our' or 'us') acknowledges the importance of safeguarding information as well as personal details and has hence, framed this policy (hereinafter referred to as the “Privacy Policy”) with respect to access and usage rights of domain name www.tutelar.io and its related sub-domains, sites, services and tools (collectively, the “Website”). Tutelar is committed to respecting your online privacy and recognizes your need for appropriate protection and management of any Information (as defined hereinafter) you share with Tutelar on the Website.
2. The Website is validly licensed to Tutelar Fintech Private Limited, a private limited company incorporated under the Companies Act, 2013, with its registered office at B20, 3rd Floor, SKCL Excellence, Guindy Industrial Estate, SIDCO Industrial Estate, Guindy, Chennai - 600032, India.
3. This Privacy Policy describes how Tutelar uses the Personal Information (as defined hereinafter ) that it collects, receives, maintains, and stores about you. This Privacy Policy does not apply to the practices of our customers that we do not own or control.
4. By accepting this Privacy Policy and using the Website, you understand and agree to the collection, use, sharing and processing of Information, as described herein. If you provide Tutelar with personal information about any third party, you confirm that they are aware that you have provided their information and that they consent to Tutelar’s use of their information according to this Privacy Policy. This Privacy Policy applies to all the current and former visitors, users and others who access the Website.
5. If you withdraw your consent or are unwilling or unable to be legally bound by this Privacy Policy, please do not use the Website. You cannot accept this Privacy Policy if: (a) you are not lawfully entitled to use the Website, or (b) if you are not of legal age to form a binding agreement with Tutelar as per applicable laws.

1. This Privacy Policy is a legally binding document between you and Tutelar.
2. By accessing or using the Website and/or availing the services provided through the Website or otherwise, giving Tutelar your information, you undertake that you have the capacity to enter into a legally binding contract vide this Privacy Policy, which constitutes a legally binding document between you and Tutelar under applicable laws, in particular, the Indian Contract Act, 1872. Tutelar collects and processes your usage data, personal data and third-party data carefully, only for the purposes described in this Privacy Policy and only to the extent necessary as defined herein and within the scope of the applicable laws and regulations. 
3. Please read the terms and conditions of this Privacy Policy along with the Tutelar Terms of Service carefully, before accessing or using this Website. This Privacy Policy shall be supplementary to the Tutelar Terms of Service. Words and expressions used in this Privacy Policy but not defined herein shall have the meanings ascribed to them in the Tutelar Terms of Service (available at https://www.tutelar.io). 
4. By accessing or using the Website including its services, you agree to the terms of this Privacy Policy. If you are accepting this Privacy Policy on behalf of another person or company or other legal entity, you represent and warrant that you have full authority to bind such person, company or legal entity to these terms.
5. Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on the Website. It is recommended that you regularly check this Privacy Policy to apprise yourself of any updates. Your continued use of Website and services, thereafter will imply your unconditional acceptance of any such updates to this Privacy Policy.

1. By mere use of the Website, you expressly consent to Tutelar’s use and disclosure of your usage information, Personal Information and third-party information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use this Website. This Privacy Policy shall be deemed to be incorporated into the terms of use of the Website (“Tutelar Terms of Service”) and shall be read with to the Tutelar Terms of Service.
2. In order to avail any service on the Website, you may be using third-party information. You hereby agree that you have obtained explicit written authorization and consent from all such subjects/individuals whose information you verify/provide data against in the format required by the applicable laws in force, from time to time and store the same in your custody basis such laws. You hereby represent and warrant that Tutelar shall not be held responsible, liable or accountable in any manner or to any extent whatsoever, for your failure to perform obligations under this Clause.
3. In case you wish to avail any or all of the services provided by Tutelar on the Website, Tutelar shall provide a username and password to you (“Login Credentials”) as set out in the Tutelar Terms of Service. You hereby explicitly agree that your use and access of the Login Credentials shall be governed by the Tutelar Terms of Service read with the terms of this Privacy Policy and any other agreement that you may enter into with Tutelar.

1. Personal Information: “Personal Information” means any information that may be used to identify an individual, including, but not limited to, the first and last names, physical address, telephone number, date of birth, age, gender, e-mail address, or any other contact information, educational qualifications, professional qualifications including past or current employer information, skill sets, project details, designations, location details, and any financial information including bank account details, credit/debit card details or such other payment information or KYC documents.
2. Business Information: “Business Information” means any information that may be used to identify an individual’s business, including but not limited to the name and address of the entity, date of incorporation, e-mail address of the entity, contact information of the registered office, company identification number (CIN), financial information including bank account details, PAN details, any other KYC documents as per RBI norms, names of the directors and such other information. 
3. Non-Personal Information: “Non-personal Information” means information that does not specifically identify an individual or business, but includes information from you, such as your browser type, the URL of the previous websites you visited, your Internet Service Provider (ISP), operating system, your Internet Protocol (IP) address. Tutelar may gather any Non-Personal Information regarding how many people visit this Website, the pages they visit, their IP address, and the type of browser they used while visiting the Website. Tutelar may also collect Non-Personal Information that you voluntarily provide, such as information included in response to a questionnaire or a survey conducted by Tutelar.
4. Usage Information: “Usage Information” includes without limitation, all data and information collected automatically through the Website (or through the third party analytics service providers), by use and access of the Website in the nature of system administrative data, statistical and demographical data, and operational information and data generated by or characterizing use of the Website including without limitation Non-Personal Information, Cookies (as defined below), Website traffic, time spent on the Website, number of visits to the Website and other similar information and behaviour indicating the mode and manner of use of the Website. 
5. Personal Information, Business Information, Non-Personal Information, Usage Information and third-party information hereinafter shall be referred to as “Information”.
6. Tutelar may collect Information from you when you (i) register on the Website; (ii) update or change personal details in your account; (iii) use the Website and for rendering services; or (iv) participate in campaigns or respond to questionnaires published by Tutelar on the Website;.
7. You hereby acknowledge and agree that all information is provided by you to Tutelar voluntarily.
8. Tutelar and its business partners may use Cookies to monitor the Website usage including, without limitation, to provide useful features to simplify your experience when you return to the Website, like remembering your login id and Information and to deliver relevant content based on your preferences, usage patterns and location.
9. Information collected by Tutelar from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.
10. You may use the Website without providing Tutelar any Personal Information about yourself. However, you may not be able to access certain services of the Websites in case you choose to do so.

1. Tutelar may use the Information you provide to fulfil your requests for the products, programs, and services, to respond to your inquiries about its offerings, and to offer you other products, programs or services that Tutelar believes may be of interest to you.
2. Tutelar uses the Information to enable it to procure information about the users. From time to time, Tutelar also may use this information to offer its products, programs, or services to them.
3. Tutelar may use the Information to monitor your use of the Tutelar services and may review and analyse the Information provided by you to provide you with customized service.
4. Tutelar may use your Non-Personal Information for internal business purposes, such as data analysis, research, developing new products, enhancing and improving existing products and services and in identifying usage trends.
5. Subject to and in accordance with applicable laws, Tutelar has the right to use your Information for the purpose of conducting promotional/marketing related activities on the Website, including but not limited to, using your Personal Information for making posters/banners to promote the services of Tutelar.
6. When you send an email message or otherwise contact Tutelar through its Website, Tutelar may use the Information provided by you to respond to your communication. Tutelar may also archive such Information and/or use it for future communications with you to inform you regarding updates, newsletters, offers, new services and promotions.

1. Tutelar maintains your Information in electronic form on its devices and on the equipment of Tutelar’s employees. The Information is made accessible to employees, agents, officers, legal advisors, auditors or partners and third-parties only on a “need-to- know” basis.
2. Tutelar does not rent, sell, or share Information with other people or with other non-affiliated entities, except with your consent, to provide services you have requested for or under the following circumstances:
3. Tutelar may engage third party vendors and/or contractors to perform certain support services, who may have access to Information.
4. Tutelar may share your information to its subsidiaries, affiliates, and group companies in order to efficiently provide certain products and/or services and/or particular features, for internal corporate/business restructuring purposes and audit related purposes etc. in compliance with applicable laws.
5. Tutelar may share your information with information technology service providers who are engaged in the provision of information technology services for fulfilling various aspects of the Website and for research and analytics.
6. In order to process your transactions, Tutelar may direct you to a payment gateway service provider of its own choice, which may have access to the Personal Information provided by you while making such payment.
7. Tutelar may share Information with government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise legal rights; to defend against legal claims; or as otherwise required by law. This may be done in response to a law enforcement agency's request.

1. Cookies are text files Tutelar places in your computer's browser to maintain your log-in and session details. Tutelar uses three types of cookies, necessary session cookies (including username, email ID, user access information) which enables Tutelar to recognise you and makes it easier for you to return to Website and interact with the Tutelar’s services without signing in again, and/or preference cookies (including search and browsing history) which are stored for the maximum duration permitted by law, and/or statistics cookies (including Usage Information such as unique request ID, statistical data) which are stored for the maximum duration permitted by law (collectively referred to as the “Cookies”).
2. Cookies, by themselves, do not tell Tutelar your e-mail address or other personally identifiable information unless you choose to provide this information to Tutelar by, for example, registering on the Website and/or by availing the services provided by Tutelar. Cookies are designed to hold a marginal amount of data specific to a particular user and website and can be accessed either by the web server or the user device.
3. However, once you choose to furnish the Website with personally identifiable information, this information may be linked to the data stored in the Cookie. Tutelar uses Cookies to understand Website usage and to improve the content and offerings on the Website. For example, Tutelar may use Cookies to personalize your experience on the Website (e.g., to recognize you by name when you return to the Website). Tutelar also may use Cookies to offer you products, programs, or services. Cookies may be placed on the Website by third-parties as well, the use of which Tutelar does not control.
4. Cookies are retained in your browser unless specifically deleted, depending on the type of Cookies. If you decline the Cookies, you may be unable to use certain features on the Website and you may be required to re-enter your password frequently. By using or accessing the Website and/or the services provided by Tutelar, you hereby explicitly authorise Tutelar and give your consent to Tutelar to store, use and access Cookies for the purposes outlined in this Privacy Policy. Most browsers allow you to control Cookies through their settings, which may be adapted to reflect your consent to the use of Cookies, and they may also enable you to review and erase Cookies.

1. Tutelar may engage third party vendors and/or contractors to perform certain support services for Tutelar, including, without limitation, software maintenance services, advertising and marketing services, web hosting services and such other related services which are required by Tutelar to provide its services efficiently. These third parties may have limited access to the Information. If they do, this limited access is provided so that they may perform these tasks for Tutelar and they are not authorized by Tutelar to otherwise use or disclose Information, except to the extent required by law. Tutelar does not make any representations concerning the privacy practices or policies or terms of use of such websites, nor does it control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Tutelar of the website, the website's provider, or the information on such website.
2. The Website may contain links and interactive functionality interacting with the websites of third parties. Tutelar is not responsible for and has no liability for the functionality, actions, inactions, privacy settings, privacy policies, terms, or content of any such website. Before enabling any sharing functions to communicate with any such website or otherwise visiting any such website, Tutelar strongly recommends that you review and understand the terms and conditions, privacy policies, settings, and information-sharing functions of each such third-party website.

• Tutelar may disclose and/or transfer Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Tutelar.

• You have the right to withdraw your consent at any point, provided such withdrawal of the consent is intimated to Tutelar in writing through an email at https://www.tutelar.io requesting the same. If you at any time wish to change or rectify your Personal Information, you may write to Tutelar as per Clause 11 of this Privacy Policy.
• Once you withdraw your consent to share the Personal Information collected by Tutelar, Tutelar shall have the option not to fulfil the purposes for which the said Personal Information was sought and Tutelar may restrict you from using the services on the Website and/or the Website itself. 
• If you wish to delete your account, and thereby discontinue using the services provided by Tutelar on the Website, such deletion of account and discontinuance of services shall be governed by the Tutelar Terms of Service read with and any other agreement that you may enter into with Tutelar. 

• You shall have the right to review your Personal Information submitted by you on the Website and to modify or delete any Personal Information provided by you directly on the Website. You hereby understand that any such modification or deletion may affect your ability to use the Website. Further, it may affect Tutelar’s ability to provide its services to you.
• Tutelar reserves the right to verify and authenticate your identity and your account Information and/or payment Information in order to ensure accurate delivery of services. Access to or correction, updating or deletion of your Personal Information may be denied or limited by Tutelar, if it would violate another person’s rights and/or is not otherwise permitted by applicable law.
• If you need to update or correct your Personal Information that Tutelar may have collected to offer you personalized services and offers, you may send updates and corrections to Tutelar at https://www.tutelar.io citing the reason for such rectification of Personal Information. Tutelar will take all reasonable efforts to incorporate the changes within a reasonable period of time.

• Tutelar shall store your Personal Information at least for such period as may be required and permitted by law. These periods vary depending on the nature of the information and your interactions with Tutelar. Such Personal Information collected by Tutelar shall only be stored in servers located in India, while ensuring compliance with statutory obligations/ regulatory instructions.
• You agree that you will not submit any false information or any illegal or damaging content to the Website. Tutelar reserves the right to terminate access to or the ability to interact with the Website in response to any concerns Tutelar may have about false, illegal, or damaging content, or for any other reason, in its sole discretion.

• Tutelar has taken adequate measures to protect the security of Information and to ensure that your choices for its intended use are honoured. Tutelar takes robust precautions to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction.
• Tutelar considers the confidentiality and security of your Information to be of utmost importance. It therefore uses industry standards, and physical, technical and administrative security measures to keep Information confidential and secure and Tutelar will not share your Information with third parties, except as otherwise provided in this Privacy Policy. Please be advised, however, that while Tutelar strives to protect Information and privacy, Tutelar cannot guarantee or warranty its absolute security when Information is transmitted over the internet into the Website. Tutelar will annually evaluate this necessity considering your privacy and Tutelar’s relation while keeping the applicable legislation in mind. Non-Personal Information will be retained indefinitely.
• Access to your online account on the Website is via. Login Credentials, which is password protected and this helps to secure your account information. You are solely responsible for maintaining the security and confidentiality of your account, including passwords and the Login Credentials. To ensure safety of your Personal Information, you are advised against sharing your Login Credentials with anyone. If you suspect
• any unauthorized use of your account, you must immediately notify Tutelar by sending an email to https://www.tutelar.io. You shall be liable to indemnify Tutelar for any loss suffered by Tutelar due to such unauthorized use of your account.
• For any loss or theft of Information, due to unauthorized access to your device through which you use the Website or other reasons solely attributable to you, Tutelar shall not be held liable or responsible under any circumstance whatsoever. Further, Tutelar shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond Tutelar’s reasonable control including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the user, etc.

• Tutelar does not intend to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions. We do not knowingly collect or solicit Personal Information from a minor or knowingly allow such persons to register for the Services. If you are a minor, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. If we learn that we have collected Personal Information from a minor without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a minor, please contact us at https://www.tutelar.io.

• You hereby agree and confirm that Tutelar shall not store or retain any Information belonging to any data subject (passed through the Tutelar’s services) at any time, save and except the metadata or hashed data for the purpose of invoicing and billing. Accordingly, Tutelar shall not in any manner be held or be responsible or liable for any and all unforeseen contingency, claims, liabilities, demands, losses, damages or expenses arising due to absence of storage or retention of any such Information which shall be your sole liability and in no event shall Tutelar be required to be present or produce any record of such Information. It shall be your sole responsibility to ensure that you have the explicit written authorisation from the data subjects (whose information is passed through the Tutelar services) as required by law and/or any contract to access, collect, store and transmit personal data of such subjects using the services of Tutelar.

• You have the option to 'opt-out' of all Tutelar’s newsletters and other general email marketing communications by way of links provided at the bottom of each mailer. Tutelar respects your privacy and in the event that you choose to not receive such mailers, it shall take all adequate steps to remove you from such lists. However, you will not be able to opt-out of receiving administrative messages, customer service
• responses or other transactional communications.

• Notwithstanding anything to the contrary contained in this Privacy Policy and/or the Tutelar Terms of Service, in case of any conflict between any terms of this Privacy Policy and/or the Tutelar Terms of Service and/or and any other agreement that you may enter into with Tutelar for availing the services, the terms of the agreement executed with Tutelar shall prevail at all times.

If you wish to make a complaint regarding any violation of the provisions of this Privacy Policy, you may send a written complaint to the grievance officer, who shall address the complaint 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:

If you have questions or concerns about this Privacy Policy, please contact Tutelar at https://www.tutelar.io.