Privacy Policy

We, at Neomercury Innovations Private Limited (“Dinero”, “Dinero AI”, “we”, “our” or “us”) understand your legitimate concern for Data protection and are committed to protecting your privacy.  

This document is published in accordance with the provisions of Rule 4 (1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under Information Technology Act, 2000 detailing our “Privacy Policy” which explains how your personal information is collected, used, and disclosed by Dinero when you visit, sign up, access, or use our products, services, content, features, technologies, or functions offered on our Website and all related sites, applications, and services (collectively referred to as “Services”).

Definitions and Key Terms:

  1. “App” shall mean the software application developed for portable computational devices by Dinero.
  2. “Company” or “Dinero” or “We” or “Our” or “Us” means Neomercury Innovations Private Limited, a company incorporated under the Companies Act 2013.
  3. “Combined Information” shall mean a combination of Personal Information and Non-Personal Information and Sensitive Personal Data or Information.
  4. “Credit Information Report” or “Credit Rating” or “Credit Score” shall mean information relating to, or an indicator of, your credit worthiness as ascertained by agencies based on details of your credit history and track record in taking and repaying loans from banks and finance companies.
  5. “Non-Personal Information” shall mean information which cannot be used to identify user’s individual identity, while using the App such as IP address, browser type, name of your internet service provider etc.
  6. “Personal Information” shall mean any information which is directly or indirectly available to Dinero to identify or verify user’s identity or to establish communication with the User including bank account details, credit and debit card details, mobile umber, e-mail address, biometric information, Credit Score, UPI ID, Government issued documents collected as a part of KYC compliance.
  7. “Sensitive Personal Data or Information” means such personal information which consists of information relating to;— (i) password; (ii) financial information such as Bank account or credit card or debit card or other payment instrument details ; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) Biometric information; (vii) any detail relating to the above clauses as provided to Dinero for providing service; and (viii) any of the information received under above clauses by Dinero for processing, stored or processed under lawful contract or otherwise: provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of these rules.
  8. "User" or "You" or "Your” shall mean any natural or legal person who has visited the App or has agreed to or has initiated the process of opening an account with Dinero or using any of Dinero’s services in any manner whatsoever.
  9. “Website” shall mean such websites as are owned and operated by Dinero as a part of its product offerings to deliver services including, and related subdomains and webpages.

Applicability & Consent:

  1. You expressly consent to share your Personal Information with our business partners, third party, collection agencies, Partner Banks with whom we have contractual arrangement for the purpose which are not limited to improving existing Services, data enrichment, generate affluence score, outsourcing relationship management activity, collection of overdue, launch of ancillary service or product.
  2. This Policy applies to any and all Users availing of any service offered by Dinero through the App or Website by registering an account, accessing and continuing the usage of content, features, functions, products, offers, and services through our Website (“Services”), you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms & Conditions of Service.

What information do we collect?

  1. In order to create an account with Dinero and to avail of the Services, you may provide us with certain Personal Data and Sensitive Personal Information. The information which may be collected by us includes the following:  
    - Personal details like name, gender, photo, phone number, date of birth, email, Aadhar number
    - Login credentials of Dinero account (include Username, M-PIN, Password and Biometric Authentication)
    - Financial details like bank account details, KYC status, UPI ID, PAN number, Credit Information Report, ongoing loans
    - Employment details like occupation, business, employment type, employment term, and salary.  
    - Residence details like address and residence type
    - Transaction details like transaction timestamp, type, amount, merchant details, OTP, password, PIN.
    - Non-Personal Information such as usage data including IP address, browser type, browser version, the pages of our Service that Users visit, unique device identifiers, and other diagnostic data, information obtained with consent from your mobile device like device location, device information (including storage, model, mobile network)
    - Information about your risk profile, investments, investment objectives, knowledge and experience, and/or business interests and assets;

How do we use the information we collect?

  1. Dinero utilizes your Personal Information or Sensitive Personal Data or Information only for specific, clear, and lawful purposes. These include:
    - To comply with government regulations including KYC. To provide a safe, smooth and efficient experience while using our App & Website;
    - To conduct credit checks or due diligence checks to minimize risks or frauds.
    - To assist you with your queries or complaints related to our Services, etc; through our dedicated customer Support Personnel;
    - To impart product knowledge, send promotional emails containing information about our existing and new products/services, newsletters, notify changes in this policy or other policies, etc;
    - To analyze User's activity on our website and to conduct market research regarding users' demographics, interests, and behaviour in order to improve our products and services;
    - To continuously improvise the products and services offered by Dinero;
    - To detect, prevent and address error, fraud, criminal activity, abuse of our services, and technical issues;
    - To enforce terms and conditions as updated from time to time;
    - To develop new products and services suitable to our User’s requirements;
    - To provide co-branded products and services in affiliation with our partner entities;
    - Other such lawful purposes as described at the time of collection of Personal Information or Sensitive personal data or information.

How long do we keep your information?

  1. Dinero will retain your personal data only for as long as is lawfully necessary for the purposes set out in this Privacy Policy or as otherwise required under any other law for the time being in force and to resolve disputes, and enforce our legal agreements and policies.

How do we protect your information?

  1. Dinero is ISO 27001 certified. We have implemented security practices and standards and have a comprehensively documented information security program and information security policies that contain managerial, technical, operational, and physical security control measures that are in compliance with applicable Indian laws and regulations.
    User data is maintained & protected with firewall configuration and stored in an encrypted format. All communication between the App and our servers stays protected via 256-bit encrypted HTTPS protocol. We utilize the industry leading antivirus software & continuously work on improvising our security system. We have secure encryption-decryption mechanisms in place with our partners to ensure the safe flow of information. Your data is accessible only to authorized personnel on a need-to-know basis to improvise our Service and to resolve your grievances. We regularly test and develop our security systems and processes to safeguard your data with cutting-edge technology. We track and monitor all access to network resources and data from time to time.  However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.
    We are complaint with Reserve Bank of India’s circular RBI/2017-18/153 DPSS.CO.OD No.2785/06.08.005/2017-2018 dated April 6, 2018, and all the data collected by Dinero’s service providers, third party vendors, and other entities in its ecosystem operated by Dinero is stored in systems within India.

Who do we share your data with?

  1. Your personal data is shared with only those entities consented by you. All such information remains safeguarded as in compliance with Indian laws regulating this space and applicable technical standards issued by international standard setting bodies. Dinero shall transfer information on a need-to-know basis for the performance of the Service. Following is a current list of our partners and the respective services they are engaged in providing to the Users through Dinero:  
    i. MMTC-PAMP Pvt Ltd. (Gold Rewards)
    5Paisa Capital Ltd. (Exchange Traded Funds)
    We may share your Combined Information with the entities that we plan to merge with or entities that we may acquire or be acquired by subject to the provisions of applicable law, in which situation we will require that the new combined entity follows Dinero’s Privacy Policy with respect to your said information.
    We may share your Combined Information without your prior consent when required by law enforcement, regulatory bodies, government officials, fraud detection agencies, financial institutions or other third parties as and when we are compelled to do so under applicable laws, courts, judicial and quasi-judicial authorities and tribunals, arbitrators, and arbitration tribunal.  

What rights do you have regarding your Personal Information?

  1. You have the right to access your information provided to us to review for accuracy and in case any personal information or sensitive personal data or information is found to be inaccurate or deficient, you may reach out to your Grievance Officer (see Clause 12) to seek adequate recourse.
  2. You have the right to not provide the data or information sought to be collected by us. In this case, however, we are unable to provide you with our Services.
  3. The Users have the right to withdraw their consent of information collection and storage given earlier by reaching out to our Grievance Officer (see Clause 12).   In this case, we will no longer make use of your data and it will be stored in our system only where the law requires us to store it.

Links to other Websites

  1. This policy discloses the privacy practices followed by Dinero’s App and Website only. Users may be redirected to partner/third party websites. These Partner websites and third parties have their own privacy policy and terms & conditions that are beyond our control. The User acknowledges that Dinero’s Policies do not cover information provided by Users on these third-party websites and Dinero is not responsible for the privacy policies, practices, or content of the linked websites. We shall in no way be responsible for your use of such sites.

Changes to Our Privacy Policy

  1. Dinero has the right to change, modify, add, or remove portions of this Privacy Policy as and when required at any time for any reason. The updated Privacy Policy will come into effect from its date of being published. We will update the "Last Updated" date at the top of this Privacy Policy. Users are advised to review this Privacy Policy from time to time.

Limitation of damages

  1. In no event shall Dinero or any of its subsidiaries, affiliates, their Directors, officers, employees, representatives, and service providers be liable to any Users for any direct, indirect, special, consequential, or other damages (including, without limitation, any lost profits, business interruption, loss of information or programs or other data on your information handling system) that are related to the use of, or the inability to use, the content, materials, and functions of this App or Website. Dinero accepts no liability for any errors or omissions, whether on behalf of itself or third parties.

Withdrawal of Consent, Modification and Grievances

  1. If you wish to withdraw your consent in relation to any of the services provided by Dinero, or any personal information or sensitive personal data or information is found to be inaccurate or deficient or have any grievance in relation to the collection, receiving, possessing, storing, dealing, or handling of said information provided by you, you may contact our Grievance Officer at the following address.

    Name: Punya Produturi
    Address: 5th Floor, Dwaraka Signature, Plot No. 14D, HITEC City, 1, Jai Hind Gandhi Rd, Madhapur, Telangana 500081

    Note that withdrawing your consent may have consequences on the services availed by you or a quality thereof. You may not be able to avail Dinero’s services in part or in full