1. Privacy Policy

1.1. Scope and Application

Brain vibe enables you to track, save and earn extra by automatically bringing your entire financial life across investments, loans, credit cards & taxes, all in one app.

1.2 This privacy policy is an electronic record in the form of an electronic contract drafted under the (Indian) Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data of Information) Rules, 2011, as amended from time to time (“Privacy Policy”).

1.3 The terms “we/us/our” shall refer to brain vibe ,  we are online Community  Located at  Brain vibe Ernakulum Reg No. UDYAM- KL – 02 -0016 – 405.  , Kerala – 683516, and the terms “you/your” shall refer to the users and any other persons accessing or seeking to use the Platform (defined below).

1.4 This Privacy Policy is a legally binding document between you and us which governs the usage, collection, protection and sharing of any information that you provide us, when you access and/or use our mobile application, Brainvibe (or “App”) (collectively, the “Platform”).

1.5 This Privacy Policy shall be read together with the other policies published by us on the Platform, including without limitation the Terms of Use and the Disclaimer (together the “Policies”).

1.6 This Privacy Policy is an electronic document and does not require any physical, electronic or digital signature. By accessing or using the Platform, you indicate that you understand, agree and consent to the terms and conditions contained in the Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, please do not use this Platform.

1.7 Please note that we are not responsible for, and this Privacy Policy does not govern information provided other than through the Platform.

2. Commitment

2.1 We are committed to ensure that your privacy is protected to all possible, reasonable and commercial extent, as your privacy and data protection is of the utmost importance to us.

2.2 For the purposes of rendering our Services through the Platform, we may collect your information from various channels, including, but not limited to, voluntary submission of information from your end in furtherance of the access or usage of the Platform, through requests initiated by you towards the Services and through communications.

2.3 You represent that the information you provide from time to time is and shall be correct, current and updated and that you have all the rights, permissions and consents to provide such information. Your providing the information to us, and our consequential storage, collection, usage, transfer, access or processing of the same shall not be in violation of any third-party agreements, laws, judgments, orders or decrees.

2.4 Please note that we are based in the Republic of India, and we are governed by the (Indian) Information Technology Act, 2000. Even though it may or may not accord the same degree of data protection as your home jurisdiction, our collection, storage and usage of information will continue to be governed by this Privacy Policy. We will always endeavour to protection of your information.

3. Types of Information collected by Us

We receive and store only that information you knowingly provide to us or with your explicit consent. You can always delete this information by writing to us at care@brainvibe.in

 Below is the list of information we collect.

New Account : When you create a new account to use the Services we request for the following information :

• Mobile number, First name, last name, PAN number(Tax Number), email, date of birth
• Income slab, profession, address details, father’s name, mother’s name, tax residency, birth country, nationality, nominee details, gender, marital status
• Bank account number, your name on bank passbook and IFSC code of the bank.

Permanent Account Number (PAN No) & Bank account details that you will use for the purpose of investments and transactions.

 KYC details: To comply with regulatory requirements, based on your explicit consent we fetch your KYC (Know Your Customer) details from regulated Central KYC Registry.

 Credit score & Liabilities information : You provide an explicit consent to BrainVibe to collect this information from third party service provider  that are expressly authorised by you to distribute such information (for example, Experian or CRIF High Mark which is a credit information company registered under the Credit Information Companies (Regulation) Act, 2005)

Access to your email is sought to provide a holistic view of your card payment due dates, statements from the applicable services etc. The BrainVibe website/app will securely store account details for each of your credit card accounts, including your sign-in user name and authorisation tokens for tracked accounts. This information will be used to enable BrainVibe website/app to automatically access your applicable credit card statements to analyze, extract, and store information securely from such accounts for use in the BrainVibe website/app.

BrainVibe will automatically access the contents of emails on an ongoing basis for the purpose of managing complete credit card lifecycle including credit card statements, due date reminders, spend patterns and related rewards etc.

5. Investments information :We provide the following options for you to update your investment information in a secure manner :

(i) Upload your investment statements in PDF or Excel versions.

These are investment statements that you get from depositories or brokers or Registrar & Transfer Agents such as Computer Age Management Services, Karvy Fintech Private Limited, National Securities Depositories Limited, Central Depositories Services Limited, etc.

You provide explicit consent to Brain Vibe to fetch these statements from https://new.camsonline.com/Investors/Statements/Consolidated-Account-Statement and https://mfs.kfintech.com/investor/General/ConsolidatedAccountStatement.

(ii) Enter the information manually

You provide investment details like scheme name, investment type, investment date and investment value by manually entering the data.

(iv) Employees Provident Fund Passbook (“EPF passbook”) details:

You can choose to provide explicit consent to BrainVibe to collect this information from https://passbook.epfindia.gov.in/MemberPassBook/Login, by providing your 12-digit Universal Account Number, assigned to you as a member of EPFO, and the related password. Your EPFO password will be stored by Brain Vibe and will be stored on our Google  server We use Firebase cloud storage by google  . This will enable Brain Vibe to consolidate and present your comprehensive EPF passbook data. This will also help you to get an accurate picture of your overall investment details on your Brain Vibe dashboard.

(v) National Pension Scheme (“NPS-Tier I”) statement details:

You can choose to provide explicit consent to Brain Vibe to collect this information from your NPS-Tier I statement assigned to you as a member of NPS-Tier I, and the related password to open the NPS Tier I statement. Your NPS-Tier I statement password will be stored by Brain Vibe. We use Firebase cloud storage by google for storing your  NPS-Tier I statement password. This will enable Brain Vibe to consolidate and present your comprehensive NPS-Tier I data as well as provide tax saving advisory which includes NPS. This will also help you to get an accurate picture of your overall investment details on your Brain Vibe dashboard.

You can choose to de-track NPS-Tier I Investments anytime from the NPS-Tier I Investments section or by writing to care@BrainVibe.in.

6.Your Expenses and Saving Account analytics via SMS (Short message service) on your Android phone (Applicable for only Android phones) :

1. You can choose to provide specific & explicit consent to allow Brain Vibe’s Android App to access your text messages (SMS) inbox received on your Android mobile device. After obtaining such explicit consent from you, Brain Vibe’s Android App may automatically read your SMS text messages pertaining to yours expenses and/or saving account balance data information arising out of transactions made from cards, banks, wallets through text messages (SMS) received by you from providers of services and/or banks (including but not limited to retail outlets, financial institutions, and utility companies) on your Android mobile device. This will enable us to organize your expenses and saving account balances across your transactions and banks in one view and also provide analytics on the same to you. This will also help you to get an accurate picture of your overall wealth and net worth on your Brain Vibe dashboard.
2. No personal SMSes or OTPs are accessed by BrainVibe.

You can choose to opt-out of the expense and saving account balance analytics services at any time by writing to  care@BrainVibe.in

Alternatively, you can also opt-out of the expense and saving account balance analytics by visiting Brain Vibe’s Android App permission settings.

1. We use various technologies and/or third-party tools to collect NPI, including without limitation:
2. Cookies: A cookie is a piece of data that any website can send to your browser, which may then be stored on your computer as an anonymous tag that identifies your computer but not you. To enhance our Services, our Platform uses cookies, sent by us or our third-party associates, or other technologies. You may control the effect of cookies through your browser settings; however, some features of our Services may not work properly if your use of cookies is disabled.
3. Web beacon or other technologies: We often use web beacon in conjunction with cookies, to enhance our Services on a number of pages of the Platform. A non-identifiable notice of a visitor’s visit to a page on the Platform is generated and recorded. Such notice may be processed by us or our third-party associates. To disable some of these features, you may disable cookies in your web browser’s settings. Web beacon and other technologies will still detect visits to these pages, but the notices they generate are disregarded and cannot be associated with other non-identifiable cookie information.

• Google Analytics or other tools: Our Platform uses certain third-party tools (including but not limited to Google Analytics), in order to evaluate your use of our Platform, and to provide other services relating to the Platform activity, among other things.

1. We may also collect other non-specific information to provide you better access to our Services each time, such as preferences and interests and other non-personal details via the Platform, any application form or email or any other medium. We may also store and publish such information to assist us in making the Platform better and easier to use.
2. Additionally, we may collect and use technical data and related information, including but not limited to technical information about your device, system and application software, and peripherals, that is gathered periodically, to facilitate the provision of software updates and other Services to you. We may use this information, among other things, to improve our Services or technologies.
3. We may disclose/share information to third-parties who support our business, such as those providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertisements, providing customer support and business support services, facilitating payments, or conducting research and surveys, and the information will be used for the limited purposes of such services received by us.

• We may also provide your information to our partners, associates, advertisers, service providers or other third parties to provide, advertise or market their legitimate products and/or services which may be of your interest. You will have the choice to ‘opt out’ of such marketing or promotional communications at your will.
• We are providing news and crypto live update, so you are bound to accept the terms and conditions , privacy policy as mentioned above. NewsData Terms and Conditions and Terms of Service | CoinMarketCap

7. Links to/from Third-Party Websites

1 The Platform may contain links to third-party websites, products, and services. Information collected by third parties, which may include without limitation information such as location data or contact details, is governed by the privacy practices undertaken by such third parties. We encourage you to learn about the privacy practices of those third parties. We expressly assert that we cannot be responsible for these practices.

2 We may have presence on social networking websites including but not limited to LinkedIn, Facebook, Twitter, YouTube, Telegram and blogs which are promotional and business initiatives to attract, engage and connect to a larger group of people. The domain links contained therein may either direct you to our Platform or request your participation by way of feedback, suggestions, etc. We, in this regard, fully disclaim any liability(ies) or claim(s), which may arise by use/misuse of your feedback, suggestions, views, etc. on any of the aforementioned networking websites or blogs, by any third party whether or not known to us.

8. Payment Related Details

1 We use secure networks for processing online payments for subscriptions. We do not store your credit card/debit card details or your internet banking details on our servers. The payment data is encrypted through the 3rd party payment gateway when processing your payments. Your purchase transaction data is only used as long as is necessary to complete your purchase transaction and is not saved thereafter.

2 The payment gateway adopted by us adheres to the standards set by PCI-DSS as managed by the RAZOR PAY, which is a joint effort of brands like Visa, MasterCard, and American Express. PCI-DSS requirements will help ensure the secure handling of payment data information by the Platform.

3 Payment gateways and other payment transaction processors will have their own privacy policies with respect to the information you are required to provide to them and we are required to provide to them for your payment-related transactions, and as such, those details will be governed by their privacy policies.

9. Operating System Permissions

1 Mobile platforms 10 (Android and iOS) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. Upon becoming operational, the IOS platform will alert you the first time our App wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that our App seeks before you first use the App, and your use of the App constitutes your consent. Sometimes these permissions require more explanation than the platforms themselves provide, and the permissions we request will change over time.

2 Android permissions:

Device & App history: We need your device permission to get information about your device, like OS name, OS version, mobile network, hardware model, preferred language, installed apps etc. Based on these inputs, we intend to optimize your overall experience by understanding your preferences and by using OS specific capabilities.

Identity: This permission enables us to know about details of your account(s) on your mobile device. We may use this info to auto-fill your email address and provide a typing free in-channel experience. It also allows facilitating your login.

Contacts: If you allow us to access your contacts, it enables us to make it easy to get referred by your friends and also send across referral links to your friends. This information will be stored on our servers and synced from your phone.

Location: If you allow us access to your location, we will be in a position to provide you a personalized experience based on your location.

Wi-Fi: When you allow us the permission to detect your wifi connection, we optimize your experience based on the connection speed.

Device ID & call information: This permission is used to detect your Android ID through which we can uniquely identify users.

10. Why does BrainVibe ask for this information?

BrainVibe is a Wealth management platform that provides online financial  Services to you. We receive information you knowingly provide to BrainVibe or with your explicit consent. This information enables you to organise and aggregate your financial information in one place on BrainVibe Services. This also enables BrainVibe to provide you analytics on your investments, liabilities & expenses all in one place. The information also enables BrainVibe Application to help you assess your risk profile from time to time and create your investment plans and enables you to manage your taxation

11. Changes to Privacy Policy

BrainVibe reserves the right to change this policy from time to time. Any changes shall be effective immediately upon the posting of the revised Privacy Policy. While we will make reasonable efforts to keep you posted on any updates to this privacy policy, to make sure that you are aware of any changes, we recommend that you review this policy periodically. If you are not comfortable with any of the changes to Privacy Policy you may choose to discontinue usage of BrainVibe website or mobile applications. You can also email us at care@BrainVibe.in to update or delete your personal information that BrainVibe has collected.

12. Privacy Questions and Access

12.1 If you have questions, concerns, or suggestions regarding our Privacy Policy, please contact us immediately at care@BrainVibe.in

In certain cases, you may have the ability to view or edit your personal information online. In the event your information is not accessible online and you wish to change or delete your personal information or other information that you may have provided, please contact us immediately care@BrainVibe.in

The Prevention of Money Laundering Act 2002 and SEBI (Investment Advisors) Regulations, 2013 require record retention for a period of up to 5 years post the deletion of your account. In the event of the pendency of any legal/ regulatory proceeding or receipt of any legal and/or regulatory direction to that effect, we may retain your information for a longer period.

12. 2 Further, any disputes regarding this Privacy Policy shall be subject to the jurisdiction of the courts of Kochi, Kerala, India.

Grievance Officer Name: Support

Email address: care@BrainVibe.in

12.3 The Grievance Officer can be contacted between 10am to 5pm from Monday to Friday except on public holidays.

13. Security and Responsible Disclosure

We at BrainVibe are committed about our client’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. The overall data and privacy security design allows us defend our systems ranging from low hanging issue up to sophisticated attacks.

If you are a security enthusiast or a researcher and you have found a possible security vulnerability on BrainVibe, we encourage you to report the issue to us responsibly.

You could submit a bug report to us at care@BrainVibe.in with detailed steps required to reproduce the vulnerability.

We shall put best of our efforts to investigate and fix the legitimate issues in a reasonable time frame, meanwhile, requesting you not to publicly disclose it. Additionally, if you have suggestions on how we could improve our security systems to make it more robust and safe for all users, you can share those with us at care@BrainVibe.in

 We encourage you to review the Privacy Policy frequently. By your continued use of the Platform, you consent to the terms of the revised/updated Privacy Policy.