Privacy Policy

Last Updated on 16th January 2025

This Application/ Website ("Platform") is operated by Dream Suite Platforms Private Limited (hereinafter referred to as "Company", "We", "Us", "Our"). We offer a technology platform that enables You to (a) view Your financial information; (b) provide access to various financial products offered by third parties and facilitate transactions between You and the distributors of such financial products; (c) carry out transactions in units of different mutual fund schemes ("Transaction(s)") of Asset Management Companies ("AMCs") ("Mutual Fund Distribution Services"); (d) avail loans and other related services ("Lending Services") offered by partner banks and NBFCs ("Lending Partners"); and/ or (e) any other services extended by the Platform from time to time ("Services").

This Policy provides information in relation to collection, possession, storage, handling and dealing of Your personal identifiable information/ data and sensitive personal data. This Policy is an electronic record in terms of Information Technology Act, 2000 and rules thereunder. We handle Your personal Information in accordance with the Digital Personal Data Protection Act, 2023 (as notified from time to time) and applicable rules and regulations and any applicable provision of Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 which have not been superseded by the relevant provisions of the Digital Personal Data Protection Act, 2023 as on the relevant date ("Applicable Privacy Laws").

The Company urges You to read and understand this Policy and the Terms of Service available at https://dreamsuite.in/termsofuse.html ("ToS") carefully. By accessing Our Platform or availing Our Services, You consent to the collection, process, use, disclosure, store and transfer of Your Personal Information in accordance with this Policy and for the purposes stipulated herein.

  1. Who does this Policy apply to?

This Policy will apply to (a) all persons accessing Our Platform; and (b) all persons using any of Our Services offered on Our Platform (hereinafter referred to as "User", "You", "Your").

  1. What data do we collect?

In the course of providing the Services to You through the Platform, We may collect the following personal information ("Personal Information"):

  1. First name and last name
  2. Phone number and email address
  3. Your billing information (like name, address, age, PAN number, bank details, wallet/ or UPI details etc.) to process payments made through the Platform for Services. All such information is stored and processed by third party payment gateways, and You are encouraged to review their privacy policy and contact them directly for responses to Your questions.
  4. Your financial information like transaction history, etc. for the financial transactions on the Platform.
  5. Your device identifiers, messages, location data, contacts, media files, camera and other device-related information as required for the provision of the Services.
  6. Any other information/ documents You may provide or upload on the Platform while using the Services on Platform.
  7. In addition to the above, We may collect some data automatically when You use the Services on the Platform, such as navigational data, Your preferences and usage patterns, manner of usage of Services etc.

When You apply for or avail Lending Services through the Platform, the Company follows a data collection approach that is strictly need-based, gathering information only when necessary. Accordingly, in addition to the information mentioned above, We may also collect the following Personal Information to facilitate use of Lending Services:

  1. Employment and income details, including but not limited to, employment or profession type, employer/ company name, mode of income, monthly in hand income;
  2. Your credit information from credit information companies, including CIBIL, Experian, Equifax, and CRIF for processing Your loan application;
  3. One time access to camera, microphone, location or any other facility necessary for the purpose of on-boarding / KYC requirements with Your explicit consent, wherever applicable; and/ or
  4. Any other additional information that the Company may require to enable Your loan application and undertake loan related operations with Lending Partners.
  1. How do we collect your data?

We collect data and process Personal Information when You:

  1. Register on Our Platform or avail Services on Our Platform.
  2. Voluntarily complete a customer survey or provide feedback on any of Our message boards.
  3. Use Our Platform, by collecting session tokens.
  4. From data that You share on or through the Platform, or while using the Services or while raising grievance through the email or ticket raising function or chat function of Platform ("Communication Function"). You are responsible for any content You share with the Company on Communication Function feature.
  5. We may receive Your Personal Information from Our partners ("Partners") with whom We have entered into certain arrangements and such data shall flow as per the agreement entered into by the Company and such Partners. We display certain Personal Information received from Our Partners for displaying on Our Platform subject to You providing consent to Our Partners. In relation to any other transfers of Personal Information from Our Partners to Us for the purpose of Our Services, We are an independent data fiduciary under the Applicable Privacy Laws and the processing of such Personal Information by Us shall be done as per this Policy.
  1. How We Use Your Personal Information?

We use the Personal Information for the following purposes:

  1. Providing Our Service: The processing of Personal Information is important to facilitate to use of Our Services to You vide the Platform as governed by Our ToS.
  2. Marketing and advertising: We use Personal Information to provide Users with special offers, and promotions, and for other marketing, advertising, and promotional purposes, including general updates about Us and Our Services and new offerings of the Company or any of its group entities or any third-party partner services. At any time, You may opt out of such communications by writing to us on support@dream.money .
  3. Enabling You to opt for services of third party: We may use Personal Information to direct You to the services or new offerings of any third-party partner services. If You wish to avail any new offerings of Our third-party partners including Lending Partners ("Third Party Service Providers"), You will be subjected to their own rules, policies, and practices of such Third-Party Service Providers and not this Policy.
  4. Improving the Services: To analyze Your choices, browsing pattern including the frequency of visits and duration for which You are logged on, to diagnose problems with Our servers, for improving Our systems and Platform and Services. We may combine the information that We receive from third parties with the information You give to Us and information We collect about You for the purposes set out above. We analyse the log files of Our Platform that may contain Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring, app crashes, page viewed and exit websites and applications, operating system, date/time stamp, and clickstream data. This helps Us to administer our Platform, to learn about user behavior on the Platform, to improve Our Services, and to gather demographic information about Our user base as a whole.
  5. Comply with legal obligations: To meet Our legal obligations under the applicable laws as well as meeting the Know Your Customer (KYC) requirements as mandated by various regulatory bodies, whose regulated service/product you opt through Our Services/Platforms.
  6. Facilitation of Payments: For facilitating the payments for You on the Platform. We share Your Personal Information with Our partner payment processors for easing Your transaction on the Platform.
  7. Legitimate Interests: To fulfil Our legitimate interests, or those of a third party in conducting and managing Our business and Our relationship with You as described in this Policy.
  8. Security: In order to protect You and other Users from fraudulent activities and transactions and to protect You and Our Platform from unauthorized access.
  9. Market research, data solutions and report creation: We may use Your Personal Information for market research and data solution purposes.
  10. Anonymization: We may anonymize and/or de-identify information collected from You through the Services or via other means, including via the use of third-party web analytic tools. As a result, Our use and disclosure of aggregated and/or de-identified information is not restricted by this Policy, and it may be used and disclosed to others without limitation. Personal Information which We may convert into the anonymized format is Our property. We may use it, in Our sole discretion and without any compensation to You, for any legitimate purpose including without limitation the transfer and commercial sale of the anonymized format to the third parties. Company may without restriction, share, use, reproduce, license, or otherwise exploit such anonymized data for its business purposes.
  1. Where is Your Personal Information stored?

The Personal Information that We collect about You is hosted in India. The storage of Personal Information by Third Party Service Providers shall be subject to their policies.

  1. Why and when do we transfer/ disclose Your Personal Information?

We may transfer Your Personal Information within India and outside India (provided that such country offers the same or greater level of protection for Personal Information than India). In relation Lending Services, where the Personal Information is required to be processed outside India for technical or operational reasons, such processing shall be carried, provided that, the data so processed will be deleted from servers located outside India and brought back to servers located in India within twenty four (24) hours of completion of such processing, as required under applicable laws. Accordingly, We transfer/ disclose Your Personal Information in the following manner:

  1. To affiliated companies and entities, within India or outside India, that have been contracted to offer services to the Company. These service providers or vendors are only permitted to use the disclosed Personal Information in accordance with the instructions provided by the Company via binding documents enforceable by law.
  2. To Third Party Service Providers including Lending Partners and AMCs with whom We have a fiduciary-to-fiduciary relationship to enable them to sell and provide their products or services to You through the Platform. Such Third Party Service Providers operate as independent fiduciaries and determine the purpose of processing Your Personal Information in accordance with their own policies, rules, and standards, and not this Policy. We do not control, monitor or assume responsibility for the processing of Your Personal Information by such Third Party Service Providers and protection of rights of data subjects under the applicable laws, data retention and storage, their security measures or other measures undertaken by them to ensure compliance with the applicable laws. The processing of Your Personal Information by such Third Party Service Providers shall be subject to their respective policies, and We encourage You to review their policies for further details on how they process Your Personal Information.
  3. To Our partner payment processors for processing of the payment for the transactions done on Platform.
  4. If required by law, legal process, litigation, and/or requests from governmental or regulatory authorities, or for the purpose of national security, law enforcement, or other issues of public importance, including cyber incidents, prosecution and punishment of offences, to disclose the User’s Personal Information.
  5. In connection with a sale, divesture, or transfer of Company (including any shares) or any combination of its products, Services, assets, affiliates, and/or businesses. The User’s Personal Information may be among the items sold or otherwise acquired in these types of transactions. We may also sell, assign or otherwise transfer such Personal Information in the course of corporate mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings.
  1. How do We protect Your Personal Information?

Security Safeguards and Procedure

We value the security of the User’s Personal Information and hence We have implemented technical and organizational security measures that are designed to help protect Your Personal Information from unauthorized access, disclosure, use and modification. From time-to-time, We review Our security procedures to consider appropriate new technologies and methods.

Please be aware, however, that no data security measures can guarantee 100% security.

If We learn of a security breach, We shall (a) attempt to notify You electronically so that You can take appropriate protective steps; or (b) post a notice on the Platform, or (c) take suo-motto steps to rectify the breach without any notice to You as per the requirements under the Applicable Privacy Laws. If You have any questions about the security of Your Personal Information, please contact the Grievance Officer as per Paragraph 13 below.

  1. How long do we keep your Personal Information?

We shall retain Your Personal Information only for as long as is necessary, and after such reasonable time, it is destroyed appropriately and securely or anonymized in accordance with the law.

We shall retain Your Personal Information (other than in anonymized form) for: (i) as long as Your account is active; (ii) as long as needed in order to comply Our legal, statutory and contractual obligations; (iii) as long as needed to provide Services to You and shall be subject to periodic update or deletion of unnecessary data.

  1. What are Your Rights and obligations in relation to Your Personal Information?

Save and except the rights provided herein in this Policy, all rights to the Personal Information shall belong to You. You shall ensure the following:

  1. To provide true and accurate details of Personal Information.
  2. To keep their information up to date.
  3. To regularly review this Policy.
  4. To keep Your account credentials confidential and notify the Company of any security breaches.

You have the following rights pertaining to the Personal Information shared by You:

  1. Right to request that the Personal Information held by Us be deleted;
  2. Right to object to the processing of the Personal Information or to request restriction thereof;
  3. Right to withdraw Your consent to submit or process any or all Personal Information or decline to provide any permissions on its Platform as covered above at any time.
  4. Right to restrict the disclosure of Your Personal Information to third parties (other than disclosures that are mandated under any statute, regulation, direction or order of a competent authority).

Any such request to delete the Personal Information, or to withdraw consent regarding sharing and use of Personal Information should be shared with the Grievance Officer as per Paragraph 13 below. Please note that We may take time to process such requests, and Your request shall take effect no later than thirty (30) business days from the receipt of such request, after which We will not use Your Personal Information for any processing unless required by Us to comply with Our legal obligations.

When You avail the Services, We may after obtaining consent by requesting device permissions, access, read, store, transfer, process and retrieve device identifiers, messages, location data, contacts, media files, and other device-related information as required for the provision of the Services. You understand that we may gain such access through relevant encryption methodologies and will utilize such data only for the limited purposes set out under this Policy. We will not store irrelevant or personal messages in any form or manner. Giving consent to access such data is entirely optional and You can revoke this consent at any time by managing Your device permissions. You may also request deletion of such data in accordance with this Policy. However, We may still retain data as may be required by applicable laws, to the extent that any amounts are outstanding, or to the extent any fraud or fraudulent transactions are suspected in connection with the Services.

In case You choose to object processing of the Personal Information, withdraw consent in regard to the Personal Information or delete the Personal Information shared, then Your access to the Platform and Services may be limited, or We might not be able to provide the Services to You.

We will evaluate any request for deletion of Personal Information on a case-to-case basis and take the requisite action as per applicable law. In this regard, please note that information sought to be deleted may remain with Us in archival records for the purpose of compliance of statutory enactments, or for any other lawful purpose or be anonymized. Therefore, You are requested to carefully evaluate what types of information they would like to provide to Us.

If You wish to exercise Your rights for protection of Your Personal Information with respect to the processing carried out by Third Party Service Providers, You must contact them directly and We shall not have any obligation in relation to it. If You reach out to Us in this regard, We may provide reasonable assistance to You to reach out to such Third Party Service Providers.

  1. Third party website/apps

We may through Our Platform, (a) provide links to third-party platforms and/ or (b) allow Third Party Service Providers to provide their services to You through Our Platform, if You opt for such services. Such Third Party Service Providers may include, without limitation, the following:

  1. the following SEBI registered investment advisors intending to offer their investment advisory services:
  1. Sigfyn Financial Services Private Limited, a SEBI registered investment advisor with registration number INA000017833. Their privacy policy and terms of use is available at www.sigfyn.com/privacy-policy and www.sigfyn.com/terms-and-conditions.
  1. the following account aggregators registered with RBI, who share personal financial data with the Third Party IAs:
  1. OneMoney, an account aggregator holding RBI license. You can visit them at https://www.onemoney.in/.
  2. Finvu, an account aggregator holding RBI license. Their privacy policy and terms of use are available at Finvu.
  1. the following other Third Party Service Providers who offer their products/ services on the Platform as per their arrangement with the Company:
  1. Upswing Financial Technologies Private Limited, a seller on Platform of fixed deposits and other financial products. You can visit them at https://www.upswing.one/.
  2. Augmont Goldtech Private Limited, a seller on Platform of digital or physical gold. Their privacy policy and terms and conditions are available at https://www.augmont.com/terms-conditions and https://www.augmont.com/privacy-policy.
  3. The relevant AMCs whose products or services may be made available through the Platform. The respective AMC’s privacy policy and terms of use may be accessed on their official websites.
  4. The relevant Lending Partners whose loan products may be made available through the Platform. The respective Lending Partner’s privacy policy and terms of use may be accessed on their official websites.

We do not make any representations or warranties with respect to such third-party platforms whose links are provided on the Platform and the Third Party Service Providers offering their products/ services on the Platform. Further, We are not responsible for the practices employed by such platforms, applications, or services linked to or from the Services or Platform, including the information or content contained there. Such third-party websites and services are subject to that third party’s own rules, policies, and practices, and not this Policy.

If You opt for and provide consent for availing such services from the Third Party Service Providers, We may share some of Your Personal Information with such Third Party Service Providers to enable You to avail such services and facilitate their services through Our Platform. Such Third Party Service Providers operate as independent fiduciaries and determine the purpose of processing Your Personal Information independently in accordance with their own policies, rules, and standards, and not this Policy. We do not control, monitor or assume responsibility for the processing of Your Personal Information by such Third Party Service Providers and their compliance with the applicable laws. The processing of Your Personal Information by such Third Party Service Providers shall be subject to their respective policies, and We encourage You to review their policies for further details on how they process Your Personal Information.

The Third Party Service Providers offering investment advisory services ("Third Party IAs") to You, with whom We have shared Your Personal information, may procure Your finance or credit related personal information from various sources legitimately available to such Third Party IAs including their account aggregators to render their services effectively. We are not investment advisors and do not provide any investment advisory services. We merely connect You to investment advisors and facilitate them in providing their services to You. In providing these services, such Third Party IAs may display such financial details on Our Platform to provide You their services. However, the Third Party IAs have sole control on such data and such data is not accessible or visible to Us. We have undertaken adequate technological measures to ensure the non-visibility and non-access of such information to Us.

  1. Should children access this Platform?

Our Services are not intended for or directed to children under the age of eighteen years. We do not knowingly collect or process personal data of children below the age of eighteen years. If We are made aware that a child under the age of eighteen years has provided their Personal Information, We will delete the information from Our records.

  1. How do We update this Policy?

This Policy is current as of the last updated date set forth above.

We may periodically change this Policy to keep pace with new technologies, industry practices, and regulatory requirements, among other reasons. While, We expect most such changes to be minor, We request the Users periodically to review the changes.

  1. Governing Law

This Policy shall be governed by and construed in accordance with the laws of India. You agree that the Company shall not be required to follow laws of any other jurisdiction, whether or not You belong to a different jurisdiction other than India.

We shall try to resolve any dispute arising out of or in relation to this Policy by mutual discussions, failing which the same shall be submitted to arbitration by the sole independent arbitrator appointed by the Company under the provisions of the Arbitration and Conciliation Act, 1996. The place of arbitration shall be Mumbai, Maharashtra, India and the language of arbitration, English. Subject to the foregoing, the courts at Mumbai, Maharashtra, India shall have exclusive jurisdiction.

  1. How to contact Us?

Any complaints with regards to use, processing or disclosure of Personal Information provided by the User or breach of the terms of this Policy may be taken up with the Grievance Officer. The details of the grievance officer are as follows ("Grievance Officer"):

Email: contact@dream.money

In case You approach the Company in relation to the grievance with Third Party Service Provider, the Company shall promptly transfer any complaints it receives from You to the Third Party Service Provider and the same shall be addressed by the Third Party Service Provider in accordance with their policies.