Reddington Financial Advisory Private Limited (“we,” “our,” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our website, ReddingtonFinance.com (the “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

1. Information We Collect

1.1 Personal Information

We may collect several types of information from and about users of our Website, including:

• Contact Information: Name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline.
• Financial Information: Bank account details, credit/debit card numbers, investment details, and other similar information necessary for processing financial transactions.
• Identification Information: Government-issued identification numbers, such as PAN, Aadhaar, or Social Security Number (for non-Indian users), to comply with regulatory requirements.
• Demographic Information: Age, gender, occupation, education level, and other similar information.
• Profile Information: Username, password, profile photo, and preferences.

1.2 Non-Personal Information

We may collect non-personal information about users whenever they interact with our Website. Non-personal information may include:

• Browser Information: Type of browser, Internet service provider (ISP), operating system, and other similar information.
• Usage Data: IP address, referring/exit pages, date/time stamps, clickstream data, and other information related to your activities on our Website.

1.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track the activity on our Website and hold certain information. Cookies are files with a small amount of data that are sent to your browser from a website and stored on your device.

• Types of Cookies Used:
  • Essential Cookies: Necessary for the operation of our Website.
  • Analytical/Performance Cookies: Allow us to recognize and count the number of visitors and see how visitors move around our Website when they are using it.
  • Functionality Cookies: Used to recognize you when you return to our Website and remember your preferences.
  • Targeting Cookies: Record your visit to our Website, the pages you have visited, and the links you have followed.

2. How We Use Your Information

We use the information we collect from you to:

• Provide Services: Process transactions, manage your account, and deliver the services you request.
• Improve Our Website: Analyze and improve our Website’s functionality, user experience, and content.
• Marketing: Send you information about products, services, and promotions that may interest you, where you have consented to receive such communications.
• Compliance: Comply with legal obligations, including KYC (Know Your Customer) and anti-money laundering regulations.
• Security: Monitor and ensure the security of our Website and your personal information.

3. Disclosure of Your Information

We may disclose personal information that we collect, or you provide, as described in this Privacy Policy:

• To Our Subsidiaries and Affiliates: For the purpose of providing our services to you.
• To Contractors, Service Providers, and Other Third Parties: We use third-party service providers to assist with certain aspects of our operations, such as payment processing, email services, and data analysis.
• For Legal Requirements: To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To Enforce Our Policies: If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Reddington Financial Advisory Private Limited, our customers, or others.

4. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures include:

• Encryption: We use encryption technology to protect your personal and financial information during transmission.
• Access Controls: Access to your personal information is restricted to authorized personnel only.
• Data Retention: We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy, or as required by law.

5. Your Rights and Choices

5.1 Access and Correction

You have the right to access, correct, or delete any personal information that you have provided to us. To do so, please contact us at the email address provided below.

5.2 Opt-Out

If you do not want us to use your information for marketing purposes, you can opt out by:

• Following the unsubscribe instructions included in our emails.
• Contacting us directly at the email address provided below.

5.3 Data Portability

You may request a copy of your personal information in a structured, commonly used, and machine-readable format. We will provide this information to you within a reasonable timeframe.

5.4 Withdraw Consent

Where we process your personal data based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

6. International Data Transfers

If you are accessing our Website from outside of India, please be aware that your information may be transferred to, stored, and processed in India where our servers are located and our central database is operated. By using our Website, you consent to the transfer of your personal information to India.

7. Third-Party Links

Our Website may contain links to third-party websites. We are not responsible for the privacy practices or content of these third-party websites. We encourage you to read the privacy policies of these websites before providing any personal information.

8. Children’s Privacy

Our Website is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn that we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes.

The Privacy Policy provided is designed to cover general privacy principles and practices that align with many of the key global data protection regulations, such as the General Data Protection Regulation (GDPR) in the European Union, the California Consumer Privacy Act (CCPA) in the United States, and India’s data protection frameworks. However, to ensure global compliance, particularly in jurisdictions with strict and specific data protection laws, the policy might need further refinement.

Key Global Compliance Considerations:

1. General Data Protection Regulation (GDPR) – European Union:

   • Legal Basis for Processing: Under GDPR, you need to specify the legal basis for processing personal data (e.g., consent, contractual necessity, legitimate interests). The policy should explicitly state these bases.
   • Data Subject Rights: GDPR grants additional rights such as the right to be forgotten, the right to object to processing, and rights related to automated decision-making. These should be clearly outlined.
   • Data Protection Officer (DPO): If required, you must appoint a DPO and include their contact information.
   • International Data Transfers: Explicitly state the mechanisms in place for transferring data outside the EU (e.g., Standard Contractual Clauses, adequacy decisions).

2. California Consumer Privacy Act (CCPA) – California, USA:

   • Consumer Rights: CCPA requires that consumers be informed of their rights, including the right to know what personal data is being collected, the right to delete personal data, and the right to opt-out of the sale of personal data.
   • Opt-Out Mechanism: Include a clear “Do Not Sell My Personal Information” link if applicable.
   • Financial Incentives: Disclose if you offer financial incentives in exchange for personal information.

3. Personal Data Protection Act (PDPA) – Singapore:

   • Consent Obligation: Ensure that the collection, use, and disclosure of personal data are based on consent, unless an exception applies.
   • Access and Correction: The policy must describe how individuals can request access to their personal data and correction if necessary.
   • Data Breach Notification: If applicable, include a procedure for notifying users of data breaches.

4. Personal Information Protection and Electronic Documents Act (PIPEDA) – Canada:

   • Openness Principle: The policy should be clear about how data is managed and should explain how individuals can exercise their rights.
   • Accountability: Identify who is responsible for your data privacy practices (this could be your Data Protection Officer or Privacy Officer).

5. Brazilian General Data Protection Law (LGPD):

   • Legal Basis: Similar to GDPR, LGPD requires a legal basis for processing personal data, which should be included in the policy.
   • Rights of Data Subjects: Include LGPD-specific rights, such as data portability, and how these can be exercised.
   • Data Processing Agreement: Ensure compliance with the need for specific contracts with third parties handling data on your behalf.

6. India’s Data Protection Framework:

   • Data Localization: If applicable, state whether you store data in compliance with local storage requirements.
   • Consent: Explicitly mention the consent process for processing sensitive personal data.

7. Cross-Border Data Transfers:

   • Standard Contractual Clauses: If you are transferring data across borders, especially from the EU, ensure you have Standard Contractual Clauses or other legal mechanisms in place.
   • Third-Country Data Processing: Mention if data is processed in countries outside of your main operating jurisdiction, and ensure this is compliant with the originating country’s laws.

8. Cookies and Tracking Compliance:

   • Cookie Consent: Particularly for the EU, a detailed cookie policy and consent mechanism compliant with the ePrivacy Directive should be included.
   • Browser DNT Signals: Address how your site responds to Do Not Track (DNT) signals.

10. Contact Information

If you have any questions or comments about this Privacy Policy, please contact us at:

Reddington Financial Advisory Private Limited
Email: [email protected]