Privacy Policy

Privacy Policy

We at Stockal are strongly committed to protect the personal and financial information that you provide to us for using our Services.

When you access, interact and/or use, as an individual, the application, website content, products and services made available through www.Stockal.com, its related domains, and mobile application platforms (collectively “Stockal Platform”) made available by Borderless Investing Inc., its subsidiaries and affiliates through its brand “Stockal”, you agree to share with us and trust us with certain sensitive and non-sensitive personal data and information (“Information”). This privacy policy (“Privacy Policy”) describes our policies and procedures on the collection, use and disclosure of your Information when you use the Stockal Platform and tells you about your privacy rights and how the law protects you.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE ACCESSING OR USING THE STOCKAL PLATFORM. YOUR ACCESS AND CONTINUED USE OF THE STOCKAL PLATFORM CONSTITUTES YOUR AGREEMENT TO BE BOUND BY THIS PRIVACY POLICY.

THIS PRIVACY POLICY EXPRESSLY SUPERSEDES ALL PRIOR AGREEMENTS OR ARRANGEMENT WITH YOU PERTAINING TO COLLECTION USE AND DISCLOSURE OF YOUR INFORMATION AND YOUR CONTINUED USE OF THE STOCKAL PLATFORM CONSTITUTES EXPRESS AGREEMENT THAT STOCKAL MAY CONTINUE USING THE DATA ALREADY ENTRUSTED TO IT IN ACCORDANCE WITH THIS PRIVACY POLICY. 

PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT CREATE ANY CONTRACTUAL OR OTHER LEGAL RIGHTS IN FAVOUR OF OR ON BEHALF OF ANY PARTY NOR IT IS INTENDED TO DO SO.

1. INTERPRETATION AND DEFINITIONS 

   1. Interpretation

In this Privacy Policy:

1. Capitalized terms not defined under ‘Definitions’ and used herein shall have the meaning assigned to them in the respective paragraph of this Privacy Policy. 

2. Terms in the singular shall include the plural and vice versa. 

3. Reference to the male gender shall include the female gender and vice versa. 

2. Definitions 

For the purposes of this Privacy Policy:

1. Account means a unique account created for you to access any parts of the Stockal Platform.

2. Application means the programming interface as independent product/services proprietary to Borderless Investing Inc., its subsidiaries and affiliates.

3. Biometrics means the technologies that measure and analyse human body characteristics, such as 'fingerprints', 'voice patterns', and "facial patterns', etc. for authentication purposes.

4. Collaborator(s) refers to certain third parties that Stockal Group works with in order to provide you with an ecosystem of services on the Stockal Platform, the names of which may be provided upon request.

5. Cookies are small files that are placed on your computer, mobile device or any other device by a website in order to remember you and your browsing history with the website.

6. Region currently includes but is not limited to the United Arab Emirates, Republic of India and United States of America. Customers from regions other than those mentioned above are requested to contact customer service. Any updates or amendments to this list shall be provided in this Privacy Policy and on the Stockal Platform and shall be deemed to be included as on the date of such updates and/or amendments;

7. Service Provider means any natural or legal person who processes the data on behalf of us. It refers to a third-party employed by us to facilitate the services on Stockal Platform;

8. Stockal Platform means when you access, interact and/or use, as an individual, the application, website content, products and services made available through www.Stockal.com, its related domains, and mobile application platforms (collectively “Stockal Platform”) made available by Borderless Investing Inc., its subsidiaries and affiliates through its brand “Stockal”;

9. Third Party Applications shall mean the third-party applications or software that integrates with the Stockal Platform, and to which this Privacy Policy, unless specified, is not applicable;

10. Third-party Social Media Service refers to any website or any social network website through which you can log in or create an Account on Stockal Platform;

11. Usage Data refers to data collected automatically, either generated by your use of the Stockal Platform or the Stockal Platform infrastructure itself (for example, the duration of a page visit);

12. “We” or “us” or “our” means, collectively, Borderless Investing Inc., its subsidiaries and affiliates through its brand “Stockal”;

13. “You” or “ your”, as applicable, refers to the user, or an individual, or other legal entity on behalf of which such individual is accessing, visiting or using the Stockal Platform, as applicable.

2. COLLECTING AND USING YOUR PERSONAL DATA 

Types of Data Collected through Stockal Platform 

In the course of your usage of the Stockal Platform, we collect, receive from you, the following types of Information.

1. Personal Data 

   1. While using the Stockal Platform, you may provide us with certain personally identifiable information including Biometrics, National Identity Document (Aadhaar card, Passport, voter ID card etc.) that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

2. We may also obtain personal information when you login using Third Party Application/Third Party Social Media Service. At the time you express interest in obtaining additional information or when you register for obtaining more information of, on or for Stockal Platform, we may also ask for additional personal information such as alternate contact numbers or age. 

3. You can update your personal information at any time by logging on to the Stockal Platform and editing your Personal Information. You can view your updated profile to confirm your edits have been made.

2. Operational Information

   1. Based on your proposed activities on the Stockal Platform, including without limitation, (i) funding your investing account, (ii) details pertaining to transactions conducted through Stockal Platform; (iii) completion of your KYC (as per the ‘Know Your Client’ requirements set by SEBI, Prevention of Money Laundering Act, 2002, and applicable United States of America related statutory requirements), (iv) completion of risk assessment and risk profiling, (v) accessing of Third Party Applications, (vi) accessing services provided on Stockal Platform through Third Party Social Media Services and/or Collaborators (“Operational Information”). You may provide additional Personal Information, which may include without limitation, certain sensitive Personal Information.

2. At all times, you agree to share the Operational Information, with such Collaborators, as may be required to adequately provide you with the services on the Stockal Platform. You understand that all Operational Information may be required to be stored for statutory purposes with us or collaborators or Third Party applications to help the relevant governments and statutory organisations fight the funding of terrorism and money laundering activities. 

3. Given the extremely sensitive nature of the Operational Information, you undertake to ensure that any information shared by you shall be true and accurate at all times, and any deviation from such accuracy and truthfulness of the Operational Information shall be notified to us. We reserve the right to restrain you from conducting any activities on the Stockal Platform based on the Operational Information at any time, without notice.

3. Non-Personal Data

   1. We may also collect non-personal information from you which shall include but not be limited to, the user device (including your mobile device unique identification, laptop and other computer operated and/or technical device identification), internet connection, geo-location, browser type, Uniform Resource Locator (URL) of the previous website or applications you visited, user Internet Service Provider (ISP), operating system, user Internet Protocol (IP) Address. Non-Personal Information cannot be easily used to personally identify you. 

   2. Generally, you may visit the website or application without telling us who you are or revealing any information about you. However, our web servers may automatically collect the domain names/IP Address of visitors. This information may be used to measure the number of visits, average time spent on the website or application and similar information, which is used to measure, evaluate performance and improve Stockal Platform.

4. Usage Data 

   1. Usage Data is collected automatically when using the Stockal Platform.

2. Usage Data may include information such as your device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of Stockal Platform that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

5. Tracking Technologies and Cookies 

   1. We use cookies and similar tracking technologies to track the activity on Stockal Platform and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Stockal Platform. Our legitimate interest is to optimize Stockal Platform, increase user experience, enhance our customer support and improve our internal process efficiency. 

2. We use Cookies to help identify your system/device so we can: 

   1. tailor user experience;

2. effectively manage the sign-up process and user management;

3. manage general administration tasks including tracking login and usage; 

4. manage newsletter or email subscription/surveys;

5. manage shopping and payment facilities. 

3. In special cases we also use Cookies provided by trusted third-parties for analytics, advertising and social media. You may at your discretion disable any Cookies already stored on your system/device, but these may affect the Stockal Platform from functioning properly. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Stockal Platform.

4. We commonly use session Cookies, which are automatically deleted by your browser after the end of your visit to the Stockal Platform. Other Cookies are stored for longer on your device and allow us to recognise you as a ‘user’ during subsequent visits to Stockal Platform. We do not pass on Information that we receive through our Cookies to third parties. By using the “Incognito” or “Private” mode of your browser, or by means of adjusting the settings in your browser, you can prevent the installation of Cookies. As a result, some of the functionality of operating Stockal Platform will no longer work.

5. We use both session and persistent cookies for the purposes set out below:

6. How the Data is Used and Shared

   1. You authorize us to use the Personal Data, Operational Information, Non-Personal Data, Usage Data and Tracking Technologies and Cookies (collectively, the “Data”) to provide services through and to improve Stockal Platform and its functionality. You agree that at all times, the Data may be shared with such Collaborators, as may be required to adequately provide you with the services on the Stockal Platform.

2. Communications: We may send periodic emails/text or instant messaging services (including WhatsApp based communications/ short messaging service (SMS)/push notifications on user device to you regarding the (i) Operational Information; (ii) Stockal Platform; or (iii) to tell you about services which we believe will be of interest to you i.e. offers, newsletters, promotions and marketing related communications for usage of Stockal Platform. These periodic emails / text or instant messaging services (including WhatsApp based communications) / SMS/ push notifications on user device, shall be delivered to the details provided by you and any change, restrictions for such email may take up to 30 (thirty) days to reflect.

3. If at any time you do not wish receive any future newsletters or marketing communications or wish to have your name deleted from our mailing lists, please follow the unsubscribe instructions included in those emails or contact us at [email protected]. We will use commercially reasonable efforts to process such requests in a timely manner. Further, we may send you administrative and transactional communications that are reasonably necessary to operate Stockal Platform and provide relevant services, such as billing, brokerage or service notifications and you cannot opt out of receiving such communications. We may also deliver notifications to your phone or mobile device. You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.

7. Security of your Personal Data 

We work hard to protect our users from unauthorized access or unauthorized alteration, disclosure, or destruction of Data we hold. In particular:

1. We encrypt our services using Secure Sockets Layer (SSL).

2. We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.

3. We restrict access to Data only to employees, contractors and agents who need to know such information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or have their business relationship terminated and proceedings brought against them if they fail to meet these obligations.

4. Identity theft and the practice known as "phishing" is of great concern to us. Safeguarding information to help protect you from identity theft is treated as top priority. We do not and will not, at any time, request a user’s credit card information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.

5. The security of your Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is one hundred percent secure. While we strive to use commercially acceptable means to protect your Data, we cannot guarantee its absolute security.

8. Use of your Data 

We use information that we collect to set up services/products for our users and may use Personal Data for the following purposes:

1. To provide and maintain the Stockal Platform, including to monitor usage of the Stockal Platform by the user.

2. To manage your Account, which includes but is not limited to managing your registration as a user of the Stockal Platform. The Data you provide can give you access to different functionalities of the Stockla Platform that is available to you as a user.

3. For the performance of a contract, i.e., the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Stockal Platform.

4. To contact you, i.e., to contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

5. To provide you with news, special offers and general information about other products, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

6. To attend and manage your requests with us.

7. We may share your Data in the following situations:

1. With Service Providers: We may share your personal information with Service Providers to monitor and analyse the use of Stockal Platform; to show advertisements to you to help support and maintain the Stockal Platform; to contact you; to advertise on third party websites to you after you visited the Stockal Platform.

2. For Business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Stockal Group assets, financing, or acquisition of all or a portion of our business to another company, on a need to know basis.

3. With Collaborators: We may share your information with our Collaborators, in which case we will require those Collaborators to honour this Privacy Policy. 

4. With other users: When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.

9. Retention, Deletion or Blocking of your Personal Data 

   1. We adhere to the principles of purpose limitation and data minimisation. We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. After discontinuation of the respective purpose or expiry of these deadlines, the corresponding data will be restricted and unavailable in accordance with statutory provisions. 

2. Our legal basis for the deletion or blocking of personal data is that it was primarily collected for specified, explicit and legitimate purposes and was limited to what is necessary in relation to the purposes for which they were collected by us.

3. We will also retain Usage Data for the purposes of internal analysis. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Stockal Platform, or we are legally obligated to retain this data for longer time periods.

4. Users may, if they wish for any reason, request in writing for the deletion of their Personal Information or their Profiles. Upon completion of such a request, we shall retain only an archival copy of such information so deleted, which shall not be accessible on the internet and will be maintained for legal compliance purposes. In this regard, you acknowledge and understand any Data that may be required to be stored for statutory purposes with Stockal or Collaborators or Third Party Applications to help the relevant governments and statutory organisations fight the funding of terrorism and money laundering activities, shall be retained by the relevant organisations as per the respective requirements.

5. Our use of information shall be in compliance with the laws governing the protection of information technology and other applicable laws in force in the Region.

10. Transfer of your Personal Data 

    1. Your information, including Personal Data, is processed at our operating offices and in any other places where the parties involved in the processing are located. 

2. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

3. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

11. International Data Transfer

    1. We may share personal information with global partners for the purpose of providing you with high quality, localized and customized services. We may use Non-Personal Information to track the use of the Stockal Platform and for other internal purposes, such as providing, maintaining, evaluating, and improving the Stockal Platform. 

2. We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from other countries law, please note that you are transferring information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information and the use and disclosure of information about you, including personal information, as described in this Privacy Policy.

12. Law Enforcement 

User email addresses and any personal customer information will not be distributed or shared with third-parties except to the extent necessary to provide you with access to Stockal Platform, or under circumstances required by law. We regularly review our compliance with our Privacy Policy. When we receive formal written complaints, we will contact the person who made the complaint to follow up on the matter. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

13. Other Legal Requirements 

We may disclose your Personal Data in the good faith belief that such action is necessary to:

1. Comply with a legal obligation or in response to valid requests by public authorities (e.g., a court or a government agency);

2. Protect and defend the rights or property of the Company;

3. Prevent or investigate possible wrongdoing in connection with the Stockal Platform;

4. Protect the personal safety of users of the Stockal Platform or the public;

5. Protect against legal liability.

14. Children's Privacy 

    1. The Stockal Platform does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Data from anyone under the age of 18 without verification of parental consent, we take steps to remove or block that information from our servers.

2. Notwithstanding n(i) above, if we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

15. Links to Other websites 

    1. Stockal Platform may contain links to other websites, Third Party Applications that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

2. Users and visitors who access a linked website, Service, Application, Payment Gateway are cautioned that they may be disclosing their private information. It is your responsibility to keep such information private and confidential. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

16. Forums and Interactive Services

There may be interactive services within the Stockal Platform, such as blogs, chat rooms, forums, instant messaging and other service member zones that allow users to input their data, details, materials, comments or other similar communications. By using such Website, Application or part of Stockal Platform, you agree that these are susceptible to unauthorised access and review, and any personal data that you published or provided during registration may become viewable by third parties. We are not responsible for the security of your information that is passed by  you to the third parties or provided during use of such website, Application or part of service on Stockal Platform. Materials that will be placed by you in such areas of the website or Application will be stored in systems/devices of the Company as per our policy, if otherwise not directly documented in each particular case.

17. Disclaimer of Warranties

We provide the Stockal Platform and all associated services on an “as is”, “with all faults” and “as available”. We make no express or implied warranties or guarantees about the Stockal Platform. To the maximum extent permitted by law, we disclaim all such warranties, including all statutory warranties, with respect to the Stockal Platform, including without limitation any warranties that the services are merchantable, of satisfactory quality, accurate, fit for a particular purpose or need, or non-infringing. We do not guarantee that the results that may be obtained from the use of the Stockal Platform will be effective, reliable or accurate or will meet your requirements. We incorporate commercially reasonable safeguards to help protect and secure your Data. However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be secure. Please note that we cannot ensure the security of any information you transmit to us, you provide us with your information at your own risk.

18. Limitation of Liability

    1. Your sole and exclusive remedy for any dispute with us is the cancellation of your registration and deletion of your Data (to the extent available with Stockal and statutorily permissible). In no event shall our total cumulative liability to you for any and all claims relating to or arising out of your use of the Stockal Platform, regardless of the form of action, exceed the total amount of fees, if any, that were paid to utilise the Stockal Platfrom in the previous three months (if any). 

2. We shall in no event be liable to you (or to any third party claiming under or through you) for any indirect, special, incidental, consequential or exemplary damages arising from your use of, or inability to use the Stockal Platform. These exclusions apply to any claims for lost profits, lost data, loss of goodwill, work stoppage, computer failure or malfunction, or any other commercial damages or losses, even if we knew or should have known of the possibility of such damages, because some states or jurisdictions do not allow the exclusion or the limitation of liability for consequential or incidental damages, in such states or jurisdictions, our liability shall be limited to the extent permitted by law.

19. Governing Law and Jurisdiction

This document shall be governed by, construed and enforced under the laws of the Region and courts in Bangalore, Karnataka shall have exclusive jurisdiction.

20. Opt-Out Policy

    1. Subject to section i(iv) above, you may opt out of being contacted by us, or receiving information either in whole or part, from us at any time by selecting the appropriate option provided in your profiles section of your user account or at any time by sending an email to [email protected]. If, at any time after registering for information or using Stockal Platform, you change your mind about receiving information from the Stockal Platform, the frequency with which you receive information or about sharing your information with third parties, you may modify your choices in the options provided on your profiles section in your user account or alternatively simply send the request to [email protected].

2. You have the right to complain about improper processing of your personal data (such as collection, storage, modification, transfer, deletion) by emailing us at [email protected].

21. Changes to this Privacy Policy 

    1. We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

2. We will let you know via email and/or a prominent notice on Stockal Platform, prior to the change becoming effective and update the "Last updated" date at the bottom of this Privacy Policy.

3. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

22. Contact us 

If you have any questions about this Privacy Policy, you can contact us at [email protected] or +91 22 42792110

* By visiting this page on our website: www.stockal.com