DATA PRIVACY & SECURITY POLICY ( Privacy Policy )

1. Introduction

By accessing, browsing, or using this Website, or by clicking “I Agree” to this Data Privacy & Security Policy and the Terms of Use, you acknowledge that you have read, understood, and agree to be bound by these terms. If you do not agree, please do not access or use the Website.

Acceptance of Privacy Policy
You expressly consent to the collection, use, sharing, retention, and processing of your Personal Information in accordance with this Privacy Policy.
You have the right to withdraw your consent at any time by contacting FinX at grievance.redressal@finxpert.org. Withdrawal of consent may result in limited access to certain features or services offered on the Website.

1.1. The website https://finxinstitute.com/ (“Website”) is owned and operated by AV Financial Experts Private Limited (“FinX”), with its office at Plot No. 112, Mezanine Floor, Above Tata Croma, Near Sion Circle, Sion Koliwada Road, Mumbai 400022.

1.2. This Privacy Policy (“Privacy Policy”) sets out the privacy practices of FinX Group with respect to the digital use.

1.3. This document is published in accordance with the provisions of the Information Technology Act, 2000 and the rules made thereunder including the Reasonable Security Practices and Procedures and Sensitive Personal Data of Information Rules, 2011, that require publishing of the privacy policy and terms of use on an online portal. We request you to go through this Privacy Policy and the terms of use available at https://finxinstitute.com/ (“Terms of Use”) carefully before you decide to access the Website and avail the services.

1.4. For the purposes of this Privacy Policy, the words “us”, “we”, and “our” refer to FinX and all references to “you”, “your” or “User”, as applicable, means the legal person who accesses, and/or uses the Website or the services in any manner or capacity, who is competent to enter into binding contracts, as per the provisions of the Indian Contract Act, 1872.

2. Purpose, Scope, Applicability

2.1. The protection and security of your Personal Information (as defined below) is our responsibility, and we have taken all necessary and reasonable measures to protect the confidentiality of the Personal Information and its transmission through the internet.

2.2. FinX is committed to safeguarding sensitive personal data, including passwords, financial details, health information, sexual orientation, medical records, biometric data, and related information (“Sensitive Personal Information”). Robust security measures, including encryption, access controls, and lawful processing practices, are to be implemented to ensure data confidentiality, integrity, and compliance with applicable laws and contractual obligations.

2.3. By using our services and the Website or by otherwise giving us your information, you agree to the terms of this Privacy Policy. You also expressly consent to our use and disclosure of your Personal Information in the manner prescribed under this Privacy Policy and further signify your agreement to this Privacy Policy and the Terms of Use. If you do not agree to this Privacy Policy, do not access or use the Website or service, or access or use any third-party product or service available through the Website, or give us your information in any manner whatsoever.

2.4. This Privacy Policy applies to all Users who handle personal data on behalf of FinX. It covers all Personal Data processed by FinX during its business operations.

2.5. Do note that this Privacy Policy does not apply to the websites maintained or services rendered by third parties whom we partner with, refer you to and/or link, and we are not responsible for any Personal Information you submit to third parties. Kindly ensure that you read the privacy policy of such third parties before submitting your details.

3. Definition

3.1. “Board” means the board of Directors of FinX as constituted from time to time.

3.2. “FinX Group” means FinX and its subsidiaries and affiliates from time to time.

4. Collection of Information

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4.1. We may collect and process information from you, through your use of the Website, or which is provided to us or one of our partners or is obtained by us through any of your engagements with us. We may collect and process Personal Information.

4.2. For the purposes of this Privacy Policy, “Personal Information” means any data which relates to an individual who may be identified from that data, that you voluntarily submit it to us or is provided to us for the purposes of providing services, or from a combination of a set of data, and other information which is in the possession of FinX, and which is not publicly available, which at all times includes:

4.2.1. any information that identifies or can be used to identify, contact or locate you, including full name, name of company/institution, designation, address, phone number, current location, email address, and other personal details that you may volunteer to provide;

4.2.2. any information that you enter into our Website at the time of subscribing to / using the services;

4.2.3. any information that you provide on our Website when you use our services including while logging in and logging out of the Website;

4.2.4. any data that is automatically captured by the Website, such as the “IP” address from which the Website has been accessed. Every computer/mobile device connected to the internet is given a domain name and a set of numbers that serve as that computer Internet Protocol or “IP” address. When you access our Website, our web servers automatically recognize your domain name and IP address; and

4.2.5. any information that is submitted in the web forms on our Website or as you use interactive features of the Website, including providing feedback or suggestions, making requests, or participation in surveys, promotions, requesting customer support, or otherwise communicating with us.

4.3. However, personal information does not include data that has been irreversibly anonymized or aggregated so that we cannot identify you through it, even in conjugation conjunction with other information available to us.

5. Use of Information Collected

5.1. Use of the Personal Information for Services

5.1.1. The primary goal of FinX in collecting Personal Information is to provide you with the Website and services. FinX may use the Personal Information provided by you in the following ways:

i) to provide you the services and access to the Website;

ii) to identify ways to improve our Website by providing better usability, troubleshooting, protection against error, fraud and other criminal activity and for maintenance of the Website;

iii) to create your user ID and/or identify you once you register on our Website;

iv) to contact you and respond to your questions or requests;

v) to remember the basic information provided by you for effective access to the Website;

vi) to notify you of any changes to the Website;

vii)to personalize and customize your services experience;

viii) for the purpose of sending administrative notices and service-related alerts and similar communication, as detailed under this Privacy Policy, with a view to optimizing the efficiency of the Website;

ix) to enable FinX to comply with its legal and regulatory obligations;

x) for internal research on our Users’ demographics, interests, and behaviour to better understand, protect and serve our Users;

xi) to do market research and project planning; and

xii)to enforce FinX’s Privacy Policy and Terms of Use as may be applicable in connection with the Website and services.

5.1.2. We collect, store, use, share, transfer, analyse, process, or otherwise handle Personal Information for the purposes mentioned above, in accordance with applicable legal requirements: (a) for legitimate business purposes; or (b) for compliance purposes; or (c) if individuals have provided consent to the same or for any purpose as defined by the applicable laws or regulations; or (d) when it is necessary for the performance of a contract to which you are a party.

5.1.3. We will limit the use, storing and processing of Personal Information in terms of scope and duration, as is necessary for the intended purpose. However, this shall not apply if it is necessary to keep the Personal Information indefinitely, or a law requires the Personal Information to be kept for a certain time.

5.1.4. WhatsApp Communication Consent: By providing your mobile number and continuing to use our services, you expressly consent to receive communications, notifications, updates, and promotional messages from FinX Group via WhatsApp. You have the right to withdraw this consent at any time by contacting grievance.redressal@finxpert.org.

5.2. Cookies

5.2.1. Cookies are small portions of information saved by your browser onto your computer / mobile phone / other devices, used for accessing our Website (“Cookies”). Cookies are used to record various aspects of your visit and assist FinX to provide you with uninterrupted services.

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5.2.2. We may use information collected from our Cookies to identify User behaviour and to serve content and offers based on your profile, to personalize your experience and to enhance your convenience of the using our Website.

5.2.3. When you use the service on the Website, we may employ web beacons which are used to anonymously track the online usage patterns of our Users. The information allows for more accurate reporting and improvement of our service. We use or may use information such as Cookies, log files, device identifiers and web beacon information to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit our Website; (ii) provide customized and personalized content and information; (iii) provide and monitor the effectiveness of our service; (iv) monitor aggregate metrics such as total number of visitors, traffic and demographic patterns; (v) diagnose or fix technology problems; (vi) help you efficiently access your information after you sign in; and (vii) provide advertising to your browser or device.

5.2.4. By using the Website, the User acknowledges and agrees that third-party service providers may utilize Cookies or similar technologies to gather information about the Users Website usage patterns. This information is collected to optimize and provide advertisements based on the Users visits on the Website and general browsing pattern of the User.

5.2.5. We neither have access to, nor do the Privacy Policy or Terms of Use govern the use of Cookies or other tracking technologies that may be placed by third party service providers on the Website. You have the ability to accept or decline cookies. We assume no responsibility or liability whatsoever for the User’s receipt or use of such tailored advertisements.

5.3. FinX pledges that it will not sell or rent your Personal Information to any third party and your Personal Information will be protected and maintained strictly confidential by FinX, provided that FinX may disclose your Personal Information in the following cases:

5.3.1. in the event it is required to do so by law, rule, regulation, governmental, legal or regulatory authorities and statutory bodies who have appropriate authorisation to access the same for any specific legal purposes;

5.3.2. in order to provide you the Services, enforce or apply the Terms of Use, or to protect the rights, property or safety of FinX, its Users or others. This includes exchanging information with other companies/agencies that work for prevention of fraud, security or technical issues;

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5.3.3. to such third parties to whom FinX transfers its rights and duties under any agreement entered into with such third parties;

5.3.4. for compliance with any judgment or decree or order issued under any law for the time being in force in India, or any judgment or order relating to claims of a contractual or civil nature under any law for the time being in force outside India;

5.3.5. transfer of Personal Information to a third party as a result of a sale or acquisition, merger or bankruptcy involving FinX.

5.4. Any third party to whom such Personal Information is divulged, is subject to a duty of confidentiality, and is required to comply with and take appropriate security measures to protect your Personal Information in line with this Privacy Policy.

6. Opt Out Procedure

6.1. You may decline to submit any Personal Information through the Website, in which case certain features of the Website may not be accessible or available to you. Upon initial communication from FinX, you may opt-out of receiving further communications from FinX. To be completely removed from the FinX mailing list, you may contact us at grievance.redressal@finxpert.org.

7. Disclosure of Information

7.1. Sharing

7.1.1. We may disclose your Personal Information for provision of Services.

7.1.2. We may also share your Personal Information with external organizations or individuals if we believe that access, use, preservation or disclosure of the Personal Information is reasonably necessary to:

i) detect, prevent or otherwise address fraud, security or technical issues; and/or

ii) protect against harm to the rights, property or safety of our customers, other Users or the public, as required or permitted by applicable law.

7.1.3. FinX will not be liable for transfer of any Personal Information resulting from loss or distribution of data, the delineation or corruption of media storage, power failures, natural phenomena, riots, act(s) of vandalism, sabotage, terrorism or any other event beyond FinX’s control. Further, FinX’s Privacy Policy does not cover the use of Cookies by its partners and affiliates since FinX does not have access or control over such Cookies.

7.2. Regulatory Disclosures

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7.2.1. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, store, transfer and disclose your Personal Information, including disclosure to third parties such as government, tax authorities or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, governmental requests or legal process; (ii) to protect the safety, rights, property or security of FinX, our services, the Website or any third party; (iii) to protect the safety of the public for any reason; (iv) to detect, prevent or otherwise address fraud, security or technical issues; and /or (v) to prevent or stop any activity we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Such disclosures under this Clause may be carried out without any notice to you.

8. Spam

8.1. FinX maintains a strict No-Spam policy, which means that FinX does not intend to sell, rent or otherwise give your Personal Information to a third party, without your consent.

9. User Testimonials, Comments, Reviews

9.1. From time to time, we may post User’s testimonials/comments/reviews with respect to the services on the Website which may contain Personal Information. We obtain User’s consent to post their names along with such User’s testimonials/comments/reviews under this Clause.

10. Security of Information

10.1. FinX has put in place necessary security practices and procedures to safeguard and secure your Personal Information. FinX only processes Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the User. The Website allows Users access to their Personal Information and allows them to correct, amend or delete inaccurate information.

10.2. FinX uses commercially reasonable precautions to preserve the integrity and security of your Personal Information against loss, theft, unauthorised access, disclosure, reproduction, use or amendment.

10.3. The Personal Information that is collected from you may be transferred to any destination within and/or outside India, to the extent permitted as per applicable law in force. By submitting Personal Information on the Website, you agree to such transfer. FinX will take such steps as it considers reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

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10.4. In using the Website, you accept the inherent security implications of data transmission over the internet. Therefore, the use of the Website will be at your own risk and FinX assumes no liability for any disclosure of Personal Information due to errors in transmission, unauthorised third-party access or other acts of third parties, or acts or omissions beyond its reasonable control and you agree not to hold FinX responsible for any breach of security.

10.5. In the event FinX becomes aware of any breach of the security of your Personal Information it will promptly notify you and take appropriate action to the best of its ability to remedy such a breach.

10.6. Audit of its security practices and procedures will be carried out by an auditor at least once a year or as and when FinX undertakes significant upgradation of its process and computer resource.

11. Data Retention

11.1. Your Personal Information will be retained with FinX as needed to provide services to you. If you have signed up for our marketing emails, we will retain your Personal Information so long as you have provided your consent to receive such communication. FinX shall not retain Personal Information longer than is necessary to fulfil the purposes for which it was collected and as permitted by applicable law. If you wish to cancel your account (if any) or request that FinX no longer uses your Personal Information to provide you services, contact us through email at grievance.redressal@finxpert.org Even after your account (if any) is terminated, FinX may retain your Personal Information as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account, investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other any other purposes as may be required under applicable law.

12. Right to Withdraw Consent

12.1. The consent that you provide for the collection, use and disclosure of your Personal Information will remain valid until such time it is withdrawn by you in writing. If you withdraw your consent, FinX will stop processing the relevant Personal Information except to the extent that FinX has other grounds for processing such Personal Information under applicable laws. FinX will respond to your request within a reasonable timeframe. You may withdraw your consent at any time by contacting FinX at grievance.redressal@finxpert.org.. Please note that your withdrawal of consent to use your Personal Information may result in us not being able to provide you with access to the Website or the services or may result in termination of any existing relationship that we may have with you.

13. Right to Correction

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13.1. You are responsible for maintaining the accuracy of the Personal Information you submit to us, such as your contact information provided to us to access the platform and avail our services. FinX relies on the Users to disclose to it all relevant and accurate Personal Information and to inform FinX of any changes. If you wish to make a request to correct or update any of your Personal Information which we hold about you, you may submit your request via email at grievance.redressal@finxpert.org.

14. No Warranty or Liability

14.1. The information, product descriptions, material, advice, suggestions, illustrations notifications, circulars, hyperlinks, etc. hosted on the Website (collectively referred to as the “Content”) is provided on an “as is” or “as available” basis. FinX disclaims any and all liability for errors or omissions and does not warrant the accuracy, adequacy or completeness of any such Content. If the said Content contains any mistakes, omissions, inaccuracies and typographical errors, etc. neither FinX nor any of its affiliates and stakeholders shall assume no responsibility thereof.

14.2. FinX reserves its right to amend the whole or any part of the Content of the Website at any time or as and when required, at its sole discretion. The Content shall not be displayed or printed in any form in part or whole without the prior written approval of FinX. Reproduction of any Content provided on the Website (with or without any modification) is prohibited (except with the prior permission of Website) and shall amount to violation of copyright and would be deemed an illegal act.

14.3. No warranty of any kind (whether it be implied, express, statutory, or relating to non-infringement of third-party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus) is given in conjunction with any services provided by FinX or Content published or hosted on the Website.

14.4. FinX shall not be liable for any loss or damage, including but not limited to any direct, indirect, special, economic, incidental, or consequential damages, losses or expenses arising in connection with the Website, the Content or use thereof or inability to use by any party, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure, even if FinX has been advised of the possibility of such damages, losses or expenses.

14.5. Please note that FinX shall not be held liable for any loss whatsoever incurred by you in respect of any data loss or theft due to unauthorized access to your electronic devices through which you access our Website. Further, the Content on the Website or the logo of FinX and/or any of its stakeholders, cannot be copied, modified, uploaded, downloaded, published or republished,

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transmitted or otherwise distributed for commercial purposes without prior and explicit permission from FinX. You are liable to indemnify FinX as per the Terms of Use/ Service Terms.

Payment Processing

1. All payments for courses, programs, or services offered by AV Financial Experts Private Limited (“FinX”) shall be processed through authorized third-party payment gateways such as Razorpay, Paytm, or any other approved payment service provider (“Payment Partner”).

2. When you initiate a payment, you may be redirected to the Payment Partner’s platform. The Payment Partner may require you to provide financial information such as credit/debit card details, UPI ID, net banking information, or other sensitive data.

3. FinX does not collect, store, or have access to your financial credentials or payment details entered on the Payment Partner’s platform.

4. You acknowledge and agree that all transactions are subject to the Payment Partner’s terms, conditions, and privacy policies. FinX shall not be responsible or liable for any failure, error, unauthorized transaction, or dispute arising from the use of third-party payment gateways.

5. Any queries, disputes, or refund requests related to payment processing must be addressed directly with the Payment Partner, in accordance with their policies, unless explicitly covered under FinX’s Refund & Cancellation Policy.

15. Notification of Changes

15.1. FinX reserves the right to amend this Privacy Policy at any time and may decide to update this Privacy Policy from time to time to reflect changes to its information practices and to ensure that the same adheres to the extant applicable regulatory requirements and standards. From time to time, any changes will be effective immediately upon the posting of the revised Privacy Policy. Please review the Privacy Policy uploaded on the Website from time to time to make sure you are aware of any changes.

16. Consent to Terms of Use

16.1. By using or accessing the Website, you acknowledge and agree that the Terms of Use are fully incorporated into and form an integral part of this Privacy Policy.

17. Grievance Officer

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17.1. In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the grievance officer (“Grievance Officer”) are provided below:

17.1.1. Grievance Officer: Ms. Madhu Raveendra

17.1.2. Email Id: grievance.redressal@finxpert.org.

17.2. It is further stated that the Grievance Officer shall redress your grievances with respect to the Personal Information provided, within 1 (one) month from the date of receipt of your written grievance to the contact details email address mentioned under this Clause.

18. Consent

18.1. By consenting to the terms of this Privacy Policy, you hereby provide express consent to FinX to collect, share, transfer, store, retain, disseminate or use the Personal Information collected by FinX in accordance with the terms of the Privacy Policy. FinX will continue to retain Personal Information provided by you until you specifically request FinX to destroy such Personal Information. However, please note that FinX shall continue to retain a copy of the Personal Information provided by you for the purpose of carrying out periodic audits and as may be required under applicable law.

19. Validity

19.1. Please contact the Grievance Officer of FinX Group for any clarifications with respect to this Privacy Policy.

19.2. If any of the provisions contained herein are found to be invalid, illegal or unenforceable in any respect, the validity, legality and enforceability of the remaining provisions shall not in any way be affected or impaired.

20. Revisions

20.1. The Policy shall be reviewed periodically and approved by the Board, and the management of FinX reserves the right to make any changes to the same, at any point in time, at all times not being in derogation of the Act or Rules.

20.2. The updated policy shall be available to all Users in case of any amendment to this Privacy Policy.

21. Governing Law and Jurisdiction

21.1. This Data Privacy & Security Policy shall be governed by and construed in accordance with the laws of India.

21.2. Any disputes arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts in Mumbai, India.

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21.3. Subject to applicable laws, FinX reserves the right to resolve any disputes through arbitration or alternative dispute resolution mechanisms, as may be deemed appropriate.