PRIVACY POLICY
GRADE CAPITAL
ATLANTEASE VENTURES INC
Grade.Capital and its mobile application is a product owned and operated by ATLANTEASE VENTURES INC an entity incorporated under the Delaware General Corporation Law, having its registered address at 8 The Green A, Dover, DE 19901, United States. (hereinafter "We", "Our", "Company", “GRADE CAPITAL” or “ATLANTEASE VENTURES INC” and "Us") which term shall include its operators, partners, licensee, successors, subsidiaries and/or affiliates.
ATLANTEASE VENTURES INC is committed to safeguard any information submitted to us on our website and/or services made available through the website or mobile applications (Collectively as the “Platform”) of Grade Capital (“Services”). This Policy provides a summary of the type of information collected and processed by us. Further, this Policy highlights the measures adopted by the company to safeguard the same.
We might authorize our affiliated group companies, subsidiaries, and third parties to utilize our Platform for presenting their products and services to you, in accordance with the relevant Terms of Use outlined on our Platform periodically.
• “Anonymous Reporting” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual user.
• “Data Breach” means any unauthorized individuals breach the security measures and unlawfully exploit sensitive or personal data that compromises the confidentiality, integrity or availability of personal data;
• “Data Processing” in relation to personal data, means a wholly or partly automated operation or set of operations performed on digital personal data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction;
• "Internet Protocol (IP)" refers to the fundamental system or protocol governing the digital formats and regulations for communication between computers within a network or interconnected networks. This is executed through the Internet Protocol Suite, commonly known as TCP/IP. Communication occurs in the form of datagrams, which are also referred to as data packets or simply packets.
• “Personal Information” means any data about an individual who is identifiable by or in relation to such data.
• “Specified Purpose” means the purpose mentioned in the notice given by the company to the user but not limited to use as enumerated in this policy for lawful purpose and enhancing the overall administration of our Platform and Services.
It is pertinent to note that we are by law required to collect information to establish the identity of the user and their beneficiaries. We advise you to peruse through our AML, CFT, CPF & KYC Policy and Terms of Use for more information. Upon providing Personal Information via our Platform or Services, you consent to the terms outlined in this Privacy Policy, explicitly granting your voluntary consent to the collection, utilizationincluding transfer outside India for lawful purposes and disclosure of said Personal Information in compliance with this Privacy Policy.
4. INFORMATION COLLECTED BY US
• As you access services on the platform, we might gather personal and financial details provided by you, like your name, phone number, email address, age, Bank Account information, investments, Aadhar or Social Security Number, PAN or Tax Identification, etc.
• It's essential to verify the accuracy of the information provided to us. If any data is discovered to be inaccurate or incorrect, please inform us immediately for necessary amendments. Please note that we cannot be held accountable for the authenticity of any information, including personal details, submitted to us. Furthermore, we may take steps as maybe outlined in our AML, CFT, CPF & KYC Policy and Terms of Use.
• Clear indications will be given when we collect Personal Information on the Platform or through the Services. Your voluntary provision of such information, for instance when applying for employment, will be recorded.
• Information will be collected when you place enquiries, share feedback or contact us via email. This data includes your name, email address, and the content of the email for our response.
• When you engage in our surveys, we may gather further details.
5. INFORMATION COLLECTION PROCESS
• We engage third-party service providers to assist in analysing specific online activities, like visitor engagement on the Platform. These service providers may utilize cookies and other technologies to conduct these analyses.
• Our servers, which could be hosted by a third-party service provider, gather information from you to enhance the functionality of our Platform and Services. This collected information includes your browser type, operating system, Internet Protocol (IP) address (an assigned number to your computer when using the Internet, which may differ between sessions), and domain name.
• To process payment transactions on our platform, we utilize authorized third-party service providers. In compliance with relevant regulations, certified third-party service providers offer tokenization services to support card transactions on our Platform. These providers handle and transfer information to card networks (such as Visa, Mastercard) as required. They possess the necessary permissions to handle, process, and transfer this information for tokenization services in accordance with applicable regulations. These third-party service providers adhere to PCI-DSS compliance. Importantly, we do not retain any data provided by you for these card transactions on our Platform.
6. USE OF INFORMATION PROVIDED TO US
The personal information you provide about yourself is used to fulfil your requests and enhance the services we offer. The Personal Information you provide will be used, not limited to, for the following:
• Identifying you within our system as a user.
• Safeguarding our services and our users including preventing and identifying potential fraudulent or abusive activities related to our services, as well as investigating any potential unlawful actions.
• Utilizing and sharing information such as demographic details, financial specifics like age, gender, Bank Account information, Aadhar or Social Security Number, PAN or Tax Identification, etc. with regulated entities (such as Investment Advisors, Research Analysts, Brokers, NBFCs, Banks) for regulatory requirements like KYC, AML, verifying against sanctions list etc., in compliance with applicable regulations and laws.
• Enhancing the overall administration of our Platform and Services.
• Providing the requested Services and improving the quality of your interaction with our Platform and Services.
• Sending emails and other notifications including distributing newsletters, surveys, offers, and promotional materials linked to our Services and for marketing purposes.
• Conducting market and customer analysis, along with market research and statistical purposes.
• Investment-related information, such as the value of holdings and returns, may also be used and shared with our managers (like Investment Advisors/Research Analysts or others) for tracking and related purposes.
• Furthermore, your demographic, financial, and investment information, as well as other data, might be disclosed to our affiliates and to other third-parties in accordance with our Terms of Use.
• Grade Capital and its platform may render its service and operate across several jurisdiction as being an offshore online platform. Accordingly, the data may be transferred and stored with reasonable safeguards as enumerated under this policy or as maybe required in the jurisdiction we may operate, whichever is more stringent.
7. DISCLOSURE TO REGULATORY AGENCIES INCLUDING THIRD-PARTIES
We are required to comply with Applicable Laws and Regulations, the guidance or direction of any regulatory authority or government agency, or any writ/ order of attachment, lien, levy, subpoena/ summons, warrant, or other legal order in the jurisdictions we operate. Accordingly, we may be required to disclose any personal information collected by us with these regulatory authorities or government agencies. Further we may share your information including personal information with third-parties including our affiliates for improving the quality of your interaction with our Platform and Services including distributing newsletters, surveys, offers, and promotional materials linked to our Services.
The company is authorized to take actions and informing relevant authorities if the Company identifies any suspicious activity on the user account. This is done keeping in mind our Anti-Bribery and Anti-Corruption Policy and Prohibition of Tipping off in line with our AML, CFT, CPF & KYC Policy.
9. THIRD-PARTY LINKS AND WEBSITES
Upon clicking a link that directs you to an external website or location, you'll exit our Platform and interact with a different site where another entity which may gather Personal Information or Anonymous Information from you. We lack control over, do not assess, and cannot be held liable for these external websites or their content. It's essential to note that the terms set in this Privacy Policy do not extend to these external websites, their content, or any information collection occurring after you click on links leading to such external websites.
"Cookies" refer to data that a browser can save following a website visit. They serve technical functions, like enhancing site navigation or preserving user preferences. Disabling cookie storage in your browser will impact your site experience.
We strive to maintain appropriate technical, operational, and physical security measures that align with the nature of our business to safeguard the information we collect.
We employ various industry-standard security technologies and protocols to safeguard your Personal Information from unauthorized access, use, or disclosure. Further, we conduct periodic reviews of these measures implemented. In the event of a breach in our security controls leading to unauthorized access to your information, we will make every effort to notify you about the extent of the breach, adhering to applicable laws and in cooperation with relevant authorities. Despite our diligent efforts to protect your information, should unauthorized individuals breach these security measures and unlawfully exploit sensitive or personal data, Grade Capital, its affiliates, and directors will not be held accountable or liable.
It is imperative to keep note that the personal information provided by you are retained until such time as maybe necessary to provide efficient services or required by law in the jurisdiction that you may reside.
13. AMENDMENTS/ REVISIONS
We reserve the right to make revisions to these Terms, with or without prior notice, by modifying this page periodically. We encourage you to regularly check this page to stay informed about any alterations made, as they will have a binding effect on you. Your ongoing use of the Services will be considered as your agreement to be bound by these Terms. Should you disagree with any part of these Terms or any subsequent changes, we strongly advise you to cease using the Online Platforms and Services immediately.
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For any general inquiries, complaints and/or giving any feedback, please email us at [email protected]
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In case you do not want to continue using our Services and want to deactivate your Account with us, please email us at [email protected].
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If you do not agree with any provision of these Terms and wish to opt out of such provision, please write to us at [email protected] (“Opt-out Request”). Please note that you are not entitled to use the Online Platforms or the Service till any decision is made on the “Opt-out Request”.