Privacy Policy

Last Updated: 8th May 2025

This Privacy Policy applies to all users of Turtle Finance (www.turtlefinance.in), including residents of India and Non-Resident Indians (NRIs), and governs how we collect, use, share, and protect your personal information in accordance with the Information Technology Act, 2000, and SEBI (Investment Advisers) Regulations, 2013.

By using our services, you agree to the practices outlined below. If you do not agree with this policy, please do not use our services.

1. Information We Collect

We collect the following categories of personal information:

Identity Information: Name, email address, phone number, nationality, PAN, and date of birth
Financial Data: Income, expenses, net worth, investment preferences, and KYC documents
Device & Usage Data: IP address, device type, browser type, cookies, usage logs
Communication Data: Records of emails, phone calls, and messages

Additionally, we may collect any information you voluntarily provide while using the Platform, subscribing to services, or interacting with advisors.

2. How We Use Your Information

Your information is used to:

Facilitate access to SEBI-registered advisors and financial professionals
Assess suitability for advice and comply with SEBI-mandated risk profiling
Personalize services and communication
Fulfill legal and regulatory requirements (e.g. tax reporting, KYC)
Improve platform functionality and user experience

We may also use aggregated or anonymized data for analytics and reporting.

3. NRI and Cross-Border Data Handling

If you are accessing Turtle Finance from outside India, including as a Non-Resident Indian (NRI), you acknowledge that your personal data will be stored and processed in India. By using our services, you consent to such transfer and processing, including disclosures required under SEBI and FEMA compliance frameworks.

4. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your data:

With SEBI-registered advisors (only upon your request or consent)
With trusted service providers (e.g., cloud platforms, payment processors, analytics tools)
With regulators or government authorities as required by law

All service providers are bound by confidentiality obligations and data protection standards.

5. Data Security

We follow industry-standard security practices, including:

SSL encryption
Secure server infrastructure
Limited access controls
Regular security audits and system monitoring

However, no system is fully immune to threats. We cannot guarantee absolute data security.

6. Your Rights

You may at any time:

Access your personal data
Request corrections or updates
Withdraw consent for specific processing activities (subject to legal and regulatory constraints)
Request deletion (if not restricted by compliance obligations)

To exercise these rights, contact us at talk@turtlefinance.in.

7. Confidentiality of Communications

All communication between you and Turtle Finance (including emails, phone calls, and documents) is intended to be confidential. If you receive information in error, please delete it and notify us. We do not guarantee that such communications are free from errors, viruses, or third-party interception.

8. Retention of Information

We retain personal data only as long as required to:

Provide our services
Comply with SEBI, tax, and KYC requirements
Resolve legal or regulatory matters

When no longer needed, we securely delete or anonymize the information.

9. Cookies and Analytics

We use cookies and third-party tools like Google Analytics to track usage patterns and improve our services. You can manage cookies via your browser settings. Disabling them may affect some website features.

10. Grievance Officer

In accordance with applicable laws, our Grievance Officer is:

Name: Mukund Lahoty

Email: talk@turtlefinance.in

We will acknowledge your complaint within 48 hours and aim to resolve it within 30 days.

11. Changes to This Policy

We may revise this Privacy Policy from time to time. Any changes will be posted on this page with a revised date. Significant updates will be communicated via email if you are an active user. Continued use of our services constitutes your acceptance of the revised policy.

Disclaimer: This policy is intended for informational purposes and does not constitute legal advice.

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