Privacy Policy

I. Introduction

1. One Club Ventures Private Limited, a company incorporated under the provisions of the Companies Act, 2013, having CIN: U74999MH2022PTC446770 and its registered office at 601, Signature Suresh Sawant Road, Off. Veera Desai Road, Andheri, Mumbai, Maharashtra, India – 400053, together with its affiliates (collectively referred to as the “Company”, “One Club”, “The 1% Club”, “We”, “Us” or “Our”), owns and operates the website available at https://www.onepercentclub.io/, its subdomains, mobile applications and other digital interfaces (collectively, the“Platform”). Through the Platform, Users may access a range of products, services and features, including research services, educational content, financial products and services (including fixed deposits and insurance products), AI-powered tools, analytical tools, market insights, communities, webinars, events and such other products, services and offerings as may be made available by us or our affiliates from time to time. Without limiting the foregoing, certain educational content, research reports, mutual fund baskets, analytical tools, market commentary, summaries, insights, recommendations and similar offerings made available through the Platform may be provided by One Centurion Ventures Private Limited, a Securities and Exchange Board of India (“SEBI”)-registered Research Analyst (Registration No. INH000023968) and Investment Adviser (Registration No. INA000018896), or such other regulated affiliates or third-party service providers as may be identified on the Platform.

2. In the course of Your access to and use of the Platform and the Services, the Company and/or its affiliates may collect, receive, store and otherwise process Personal Data and Non-Personal Data to provide, operate, maintain, improve and secure the Platform and the Services, facilitate access to products and services made available through the Platform, comply with Applicable Law and regulatory requirements, and enhance Your overall user experience. We are committed to safeguarding Your information and have implemented reasonable and appropriate technical, organisational and administrative measures to protect the confidentiality, integrity and security of the information processed by us.

3. This Privacy Policy applies to Your access to and use of:

• a) the website https://www.onepercentclub.io/ and any subdomains, linked pages, microsites or webpages operated by us;
• b) mobile applications owned, operated, licensed or made available by us;
• c) all features, services, products, tools, content, subscriptions, communities, courses, educational material, financial content, research-related access, third-party product access, AI-powered tools, chatbots and related functionalities made available through the website or application; and
• d) any communication, interaction, transaction or engagement between You and us through email, telephone, WhatsApp, SMS, push notification, chatbot, social media, customer support, events, webinars or any other mode.

4. The Privacy Policy is published in accordance with Rule 4(1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPI Rules”) and Section 5 of the Digital Personal Data Protection Act, 2023 (“DPDP Act”), read with Rule 3 of the Digital Personal Data Protection Rules, 2025 (“DPDP Rules, 2025”), and applicable SEBI/Exchange regulations and directions.

5. This Privacy Policy is to be read together with our Terms and Conditions, refund/cancellation policy, risk disclosures, service-specific terms, consent forms, disclaimers and any other policies or notices made available by us from time to time.

6. You are advised to read the terms of this Privacy Policy carefully before accepting. By accessing or using the Platform, creating an account, subscribing to any Service, making payment, submitting information, providing consent, clicking “I Agree”, “Accept”, “Continue”, “Subscribe”, “Pay Now” or any similar button, or continuing to use the Platform, You confirm that You have read, understood, acknowledged and agreed to this Privacy Policy, and hereby, voluntarily and expressly consent to the collection / sharing / processing / use / storage and disclosure of Your Personal and Non-Personal Data by Us and our affiliate companies, as prescribed in this Privacy Policy.

7. If You do not agree with this Privacy Policy, You must not access or use the Platform or Services.

II. Definitions

8. For the purposes of this Privacy Policy:

• a) “Applicable Law” means all applicable laws, rules, regulations, notifications, circulars, guidelines, directions, orders and regulatory requirements in force in India, including the Information Technology Act, 2000, SPI Rules, DPDP Act, and any other applicable Indian law.
• b) “Consent” means any freely given, specific, informed, unconditional and unambiguous indication of Your agreement to the processing of Your personal data for a specified purpose, whether by electronic means, clickwrap acceptance, checkbox, OTP validation, continued use, account creation, submission of information or any other affirmative action.
• c) “Data Fiduciary” shall have the meaning assigned to it under the Digital Personal Data Protection Act, 2023.
• d) “Data Principal” shall have the meaning assigned to it under the Digital Personal Data Protection Act, 2023 and shall refer to the individual to whom the personal data relates.
• e) “Non-Personal Data”includes any information which cannot be used to identify an individual, while he / she uses the Platform. This information includes IP address, browser type, time zone setting, login information, name of the individual's internet service provider, etc.
• f) “Personal Data” means any data about an individual who is identifiable by or in relation to such data.
• g) “Platform” means the website, mobile application, digital interface, features, tools, content, services and other online/offline interfaces operated or made available by us.
• h) “Processing” means any operation performed on personal data, including collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment, indexing, sharing, disclosure, transmission, dissemination, restriction, erasure or destruction.
• i) “Service” or “Services” means all services, offerings, features, products, tools, subscriptions, memberships, educational content, financial content, research-related access, third-party products, AI-powered tools, community features, customer-support features, events, webinars, communications and other functionalities provided or facilitated through the Platform.
• j) “Third-Party Service Provider” means any third party, partner, affiliate, group entity, vendor, consultant, intermediary, payment gateway, technology provider, cloud provider, analytics provider, customer-support provider, communication provider, KYC provider, financial-product provider, research analyst, insurer, bank, NBFC, depository participant, broker, registrar, transfer agent, regulatory body, statutory authority or any other person/entity with whom information may be shared for lawful purposes.

III. Scope of this Privacy Policy

9. This Privacy Policy explains the categories of information that we collect and the manner in which such information is collected, received, used, processed, stored, retained, secured, disclosed and otherwise handled by us. It also sets out the purposes for which we process Your information, the lawful bases and consent framework applicable to such processing, and the circumstances in which Your information may be shared with third parties.

10. This Privacy Policy describes Your rights under Applicable Law, the manner in which You may exercise such rights, including by withdrawing Your consent or raising grievances, as well as the safeguards, limitations and other practices governing our processing of Your information.

11. This Privacy Policy applies to all Users, visitors, subscribers, members, learners, customers, prospective customers, participants, community members and any other persons who access or interact with the Platform or Services.

IV. Information We Collect

12. Depending on Your access to and use of the Platform and the Services, we may collect, receive, generate and otherwise process Personal Data and Non-Personal Data. The categories of information that we may collect include the following:

(i) Account and Profile information

13. We may collect information required to create, operate, authenticate and manage Your account or membership with Us, including:

• full name, username or account ID;
• email address; and mobile number;
• password or authentication credentials, in encrypted or protected form;
• profile photograph, where voluntarily provided;
• date of birth;
• gender, where voluntarily provided or required for a specific Service;
• city, state, country and general location details;
• occupation, professional background, education or income bracket, where relevant to a Service;
• communication preferences; and
• any other information provided by You during registration, onboarding or account management.

(ii) Identity, KYC and Verification information

14. Where required for enabling You to access or avail any Service on the Platform, including any third-party product(s), regulated product(s), research-related services, financial products, fixed deposits, insurance products, or facilitate the completion of any payment, compliance or legal obligations therein, We or the relevant service provider may collect or facilitate the collection of:

• PAN, Aadhaar-related information, only where lawfully permitted and subject to applicable requirements and CKYC/KYC details;
• Photograph and signature;
• date of birth, address proof and identity proof;
• bank account details, nominee details, where applicable and tax residency details;
• suitability/risk-profile information;
• FATCA/CRS or similar declarations, where applicable;
• income range, investment objective, risk appetite, investment horizon and financial profile;
• regulatory declarations and consent records; and
• any other information required by law, regulators, intermediaries or service providers.

(iii) Financial and transaction information

15. We may collect and process financial, subscription and transaction-related information, including:

• subscription plan selected by You;
• fees, invoices, payment status, transaction history, payment method details, subject to applicable payment-security standards; and payment gateway transaction IDs;
• refunds, chargebacks, failed payments and disputes;
• coupon, referral or promotional usage;
• financial-product applications submitted through or facilitated by the Platform;
• investment, fixed deposit, insurance, research-service or other product-related journey information;
• service usage linked to paid memberships or subscription tiers; and
• records required for accounting, tax, audit, fraud prevention and legal compliance.

16. We do not ordinarily store complete card numbers, CVV, UPI PINs, net-banking passwords or other sensitive payment credentials. Such information is processed by authorised payment gateways, banks or payment service providers in accordance with applicable law and their own security standards.

(iv) Educational, learning and usage information

17. Where You access courses, communities, events, webinars, tools or educational content, we may collect and store:

• Information regarding courses, modules, videos, sessions or content accessed by You;
• progress, completion status, assessments, quizzes or participation records;
• webinar attendance and event participation including questions, comments, assignments, feedback or responses submitted by You;
• community participation, engagement and certificates, badges or completion records;
• downloaded resources or templates; and
• interaction history with educators, mentors, coaches, support teams or community managers.

(v) Research, financial content and product interaction data

18. Where the Platform provides access to financial content, research-related services, model portfolios, analytical tools, market commentary, fixed deposit products, insurance products, third-party products or affiliate services, we may collect:

• products, tools, pages, reports or content viewed by You; research-service access logs;
• watchlists, preferences, filters and saved items;
• risk-profile or suitability responses, investment objectives and declarations required for conducting suitability assessments facilitating access to Services or products, or complying with Applicable Law;
• consent and acknowledgement records for disclaimers, MITC, investor charters and risk disclosures as may be required by the Investment Adviser or the Research Analyst;
• redirection, application or onboarding information for third-party providers;
• transaction status or product application status received from third parties;
• service-specific consents; and
• information required to demonstrate regulatory compliance.

(vi) AI Tool, Chatbot and automated interaction data

19. If You use AI-powered tools, chatbot services, automated assistance features or similar functionalities, we may collect and store:

• prompts, questions, commands, inputs or messages submitted by You;
• AI-generated responses and outputs;
• usage logs and interaction history;
• feedback on AI responses;
• files, text or other content voluntarily uploaded or submitted by You;
• technical data used to improve tool performance, safety and reliability; and
• metadata relating to AI-tool interactions.

20. You are advised against submitting any passwords, OTPs, banking credentials, trading credentials, health information, confidential third-party information, unpublished price-sensitive information, legally privileged information, or any other sensitive or unlawful information into any AI tool or chatbot unless, specifically required and expressly permitted by us for a lawful purpose.

(vii) Communications and customer support information

21. When You contact us or interact with our teams, we may collect:

• emails, calls, chats, WhatsApp messages, SMS and other communications;
• customer-support tickets, complaints, grievances and dispute details;
• call recordings, where lawfully recorded with notice/consent;
• feedback, survey responses and testimonials;
• communication preferences and opt-out records.

(viii) Device, technical and usage information

22. When You access or use the Platform, we may automatically collect:

• IP address, device ID, advertising ID and other similar identifiers;
• Browser type and version, operating system, mobile network information, device type, model, settings and app version;
• Login time, access time, session duration, clickstream data, pages, screens, features and links accessed, and referring URLs;
• Crash logs, diagnostics, performance data, security logs and authentication logs;
• Approximate location derived from Your IP address or device settings; and
• Fraud-detection signals and other information used to protect the Platform and its users.

(ix) Cookies and similar technologies

23. We may use cookies, pixels, tags, SDKs, local storage, web beacons and similar technologies to enable login and authentication, remember Your preferences, analyse Platform traffic and usage, understand user behaviour, detect fraud and security incidents, improve the performance and functionality of the Platform, personalise content and communications, measure the effectiveness of marketing campaigns, and support advertising, marketing or retargeting activities, where permitted under Applicable Law. Third-party analytics and advertising partners may also use cookies, SDKs or similar technologies, subject to their own privacy policies.

24. You may control or disable cookies through Your browser or device settings. However, disabling cookies may affect the availability or functionality of certain Platform features.

(x) Marketing, referral and campaign information

25. Where You participate in referral programmes, campaigns, promotions, events, offers or marketing activities, we may collect:

• referral codes and referral activity;
• campaign participation details;
• lead-source information;
• marketing preferences;
• offer eligibility;
• promotional communications opened or clicked;
• event registration and attendance details; and
• information required to prevent misuse, abuse or fraudulent claims.

(xi) User-generated content

26. Where You post, upload, submit, transmit or share any content on the Platform, including comments, posts, reviews, testimonials, community messages, queries, feedback, images, videos, assignments or other material, we may collect, store, moderate, review, display, analyse and process such content in accordance with this Privacy Policy, the Terms and Applicable Law.

(xii) Information from Third Parties

27. We may receive information about You from:

• affiliates and group companies;
• payment gateways and banks;
• KYC and verification providers;
• brokers, depository participants, registrars, transfer agents and other intermediaries;
• insurers, banks, NBFCs, research analysts and financial-product providers;
• analytics and marketing partners;
• social media platforms, where You interact with us;
• referral partners;
• publicly available sources;
• regulatory authorities, law enforcement agencies or courts; and
• other lawful sources.

V. How We Collect Information

28. We may collect information:

• a) directly from You when You register, subscribe, make payment, submit forms, use Services, contact us or interact with the Platform;
• b) automatically through cookies, SDKs, logs, analytics tools and device technologies;
• c) from affiliates, group companies and service providers;
• d) from third-party providers where You choose to access their products or services through the Platform;
• e) from payment, KYC, verification, communication, cloud, analytics and technology providers;
• f) from regulatory, statutory, law enforcement or dispute-resolution bodies;
• g) to develop new products, services, features and analytical insights;
• h) from publicly available or lawfully accessible sources; and
• i) from Account Aggregators, where You provide Your explicit consent through the applicable consent artefact for the retrieval and sharing of Your financial information, in accordance with Applicable Law.

VI. Purposes for Which We Use Personal Data

29. We may use, process, store and disclose Your information for the following purposes.

(i) Account creation and Platform access

30. We may process Your Personal Data and Non-Personal Data to create, operate and manage Your account or membership with Us, verify Your identity, authenticate Your login credentials, enable Your access to the Platform and the Services, maintain the security of Your account, detect unauthorised access or suspicious activity, and provide account-related support and assistance.

(ii) Service delivery

31. We may process Your data to provide, operate, maintain and improve the Platform and the Services, deliver subscriptions, memberships, educational content, courses, tools, events, webinars and community features, facilitate the execution of agreements, onboarding, suitability assessments, investment journeys and other regulatory or compliance requirements applicable to financial products or regulated Services, enable access to free or paid Services, provide user dashboards and personalised features, facilitate research-related Services, affiliate Services and third-party Services, process service requests and customer support queries, and administer offers, benefits, memberships and subscription tiers.

(iii) Financial Product and Third-Party service facilitation

32. Where You choose to access third-party or affiliate products/services through the Platform, We may process information to facilitate onboarding with the relevant provider, undertake KYC, identity verification, suitability assessments and regulatory declarations, facilitate access to fixed deposits, insurance products, research-related Services, analytical tools, model portfolios and other products or Services, transmit applications, declarations, consents and status updates, comply with Applicable Law and the requirements of the relevant provider, provide customer support in coordination with third-party providers, and maintain records of Your consent, access and usage.

(iv) Payments, Billing and Tax

33. We may process Your information to process payments, generate invoices and receipts, verify payment status, process refunds where applicable, manage chargebacks, disputes and failed payments, comply with accounting, audit and taxation requirements, and prevent payment fraud, misuse or unauthorised transactions.

(v) Personalisation and User experience

34. We may process Your information to personalise content, recommendations, tools and communications, understand Your preferences and usage patterns, improve the design, functionality and navigation of the Platform, provide relevant educational, informational and product-related content, develop user insights and analytics, and improve the quality of the Services and User engagement.

(vi) AI Tools and automated features

35. We may process Your Personal Data and Non-Personal Data to operate AI-powered tools, chatbots and other automated features, generate responses to Your queries, improve the quality, relevance, safety and reliability of AI-generated outputs, detect misuse, harmful prompts or unlawful content, maintain logs for audit, security, safety, support and troubleshooting purposes, and improve our products, Services and overall user experience.

36. AI-generated outputs may be inaccurate, incomplete or unsuitable for Your specific circumstances. You should independently verify all outputs and should not rely on them as professional, legal, tax, investment, insurance, medical or financial advice.

(vii) Marketing and communications

37. Subject to Applicable Law and Your communication preferences, we may process Your Personal Data and Non-Personal Data to send service, transactional and account-related communications, provide updates relating to subscriptions, courses, events, webinars, products, tools, features and Services, send promotional, educational and marketing communications, administer offers, discounts, referral programmes and promotional campaigns, communicate with You through email, SMS, WhatsApp, telephone calls, push notifications, in-app notifications and other electronic communication channels, and measure the effectiveness of our marketing activities and campaigns.

38. You may opt out of receiving promotional or marketing communications at any time. However, we may continue to send communications relating to Your account, security, payments, transactions, regulatory requirements, customer support or other essential Service-related matters.

(viii) Security, fraud prevention and misuse detection

39. We may process Your information to protect the Platform, the Services, Our users, affiliates, partners and systems, detect, prevent and investigate fraud, piracy, credential sharing, unauthorised access, scraping, bots, malware and other abusive or unlawful activities, detect suspicious transactions, payment fraud and chargeback abuse, investigate actual or suspected violations of our Terms or policies, enforce our contractual and legal rights, and protect our business, reputation, systems and legitimate interests.

(ix) Legal, regulatory and compliance purposes

40. We may process Your Personal Data and Non-Personal Data to comply with Applicable Law and our legal, regulatory and compliance obligations, including requirements prescribed by SEBI, RBI, IRDAI, consumer protection, information technology, data protection, tax and other applicable laws and regulations.

41. We may also process such information to respond to lawful requests or directions from courts, tribunals, regulators, statutory authorities, government agencies and law enforcement authorities, maintain statutory, regulatory, audit and compliance records, assist our affiliates and third-party service providers in complying with their legal or regulatory obligations, investigate complaints, grievances and disputes, enforce our legal rights, defend legal claims, and prevent, detect or investigate illegal, fraudulent, unauthorised or other harmful activities.

(x) Business operations and corporate transactions

42. We may process Your Personal Data and Non-Personal Data for our internal business operations, including conducting internal audits, compliance reviews, risk assessments, business analytics and reporting, and managing our relationships with vendors, affiliates, partners and other service providers. We may also process such information in connection with any corporate restructuring, merger, acquisition, investment, financing, business transfer, asset sale or other similar corporate transaction, including for the purposes of due diligence and compliance with contractual, legal and regulatory obligations arising in connection with such transaction.

VII. Lawful Basis for Processing

43. We process Your Personal Data where:

• a) You have provided Consent;
• b) processing is necessary for providing Services requested by You;
• c) processing is necessary for performance of a contract or pre-contractual steps;
• d) processing is necessary for compliance with Applicable Law;
• e) processing is necessary for responding to a medical emergency, disaster, legal obligation or court/regulatory direction, where applicable;
• f) processing is necessary for employment-related or business purposes in accordance with law, where applicable;
• g) processing is necessary for legitimate business purposes, including fraud prevention, platform security, analytics, service improvement, legal claims and business operations, subject to Applicable Law; or
• h) processing is otherwise permitted under Applicable Law.

44. Where Consent is required under Applicable Law, we will process Your Personal Data based on such Consent. You may withdraw Consent in accordance with this Privacy Policy, subject to consequences explained below.

VIII. Consent

45. By accessing or using the Platform, submitting information, creating an account, making payment, accepting this Privacy Policy, opting into a Service, completing onboarding, clicking any consent checkbox, validating through OTP, or otherwise providing information, You consent to the collection, storage, use, processing, disclosure, sharing, transfer and retention of Your information in accordance with this Privacy Policy.

46. Where specific consent is required for any Service, financial product, affiliate service, third-party product, research-related service, KYC, AI tool, marketing communication or other activity, we may request separate or additional consent.

47. You represent that all information provided by You is true, accurate, complete, current and lawful. You agree to promptly update Your information if it changes.

48. Where You provide information relating to another person, including nominee details, family member details, referral details, beneficiary details or emergency contact details, You represent that You have obtained valid consent from such person and are authorised to provide such information to us.

IX. Withdrawal of Consent

49. You may withdraw Your Consent by contacting us at support@onepercentclub.io or through such mechanism as may be provided on the Platform.

50. However, withdrawal of Consent may affect our ability to provide certain Services. If the relevant information is necessary for account operation, compliance, payment, product onboarding, KYC, fraud prevention, legal claims, regulatory obligations or service delivery, we may be unable to continue providing the relevant Service after withdrawal of Consent.

51. Withdrawal of Consent shall not affect any processing undertaken prior to such withdrawal, any processing required or permitted under Applicable Law, or any processing necessary for compliance with legal or regulatory obligations, legal claims, dispute resolution, audit, fraud prevention, security, enforcement of Our rights or legitimate business interests. Withdrawal of Consent shall also not affect the retention of Personal Data and Non-Personal Data where such retention is required or permitted under Applicable Law, by regulatory authorities, tax authorities, payment service providers, financial product or Service providers, or for internal audit, compliance or record-keeping purposes. Further, nothing in this Privacy Policy shall restrict Our right to retain, use or process anonymised, aggregated or de-identified information that does not identify You.

X. Sharing and Disclosure of Information

52. We may share Your information with the following categories of persons/entities, to the extent necessary for lawful purposes.

(i) Affiliates and group companies

53. We may share information with our affiliates, group companies, subsidiaries, associates and related entities, including entities providing research-related services, educational services, financial content, technology support, customer support, analytics, marketing, product development, compliance or other lawful services.

54. Each such entity may process information in accordance with this Privacy Policy, its own privacy policy, service-specific terms and Applicable Law.

(ii) Third-Party Service Providers

55. We may share Your Personal Data and Non-Personal Data with vendors and third-party service providers who assist us in operating, maintaining, securing and improving the Platform and providing the Services.

56. Such service providers may include cloud hosting and data storage providers, IT infrastructure, CRM and workflow service providers, payment gateways, payment processors, KYC and verification service providers, communication service providers facilitating email, SMS, WhatsApp, telephone calls and push notifications, analytics and marketing service providers, customer support platforms, fraud prevention and cybersecurity service providers, legal, accounting, audit and compliance advisers, and other technology, operational or professional service providers engaged by us for lawful business purposes.

(iii) Financial product and regulated service providers

57. Where You choose to access financial products or regulated services through the Platform, we may share Your information with relevant providers, including:

• a) SEBI-registered Research Analysts;
• b) brokers, depository participants, Registrar and transfer agents, asset management companies, exchanges or market infrastructure institutions, where applicable;
• c) banks and NBFCs;
• d) fixed deposit issuers;
• e) insurers and licensed insurance intermediaries;
• f) payment aggregators and payment service providers;
• g) KYC registration agencies and verification providers;
• h) regulatory platforms and reporting utilities; and
• i) any other registered, licensed or authorised provider relevant to the Service.

58. Such providers may process Your information independently in accordance with their own terms, privacy policies, regulatory obligations and Applicable Law.

(iv) Business partners and referral partners

59. Where You access offers, promotions, events, webinars, co-branded services, referral programmes or partner benefits, we may share relevant information with business partners, subject to Applicable Law and applicable consents.

(v) Legal, regulatory and government authorities

60. We may disclose Your information to courts, tribunals, regulators, statutory authorities, law enforcement agencies, government departments, tax authorities, SEBI, RBI, IRDAI, stock exchanges, depositories, consumer forums, ombudsman platforms, grievance platforms, dispute-resolution bodies or other authorities where required or permitted by law.

(vi) Corporate transactions

61. We may disclose or transfer information in connection with any merger, acquisition, investment, financing, restructuring, reorganisation, business transfer, asset sale, insolvency, due diligence or similar corporate transaction, subject to reasonable confidentiality safeguards and Applicable Law.

(vii) Protection of rights and safety

62. We may disclose information where We believe in good faith that such disclosure is necessary to:

• a) enforce our Terms, policies or agreements;
• b) protect our rights, property, business, users or partners;
• c) detect or prevent fraud, security incidents, illegal activity or misuse;
• d) respond to user complaints, chargebacks, claims or disputes;
• e) prevent harm to any person; or
• f) protect the integrity and security of the Platform.

XI. Third-Party Services and Links

63. The Platform may contain links, integrations, APIs, SDKs, redirects or access points to third-party websites, applications, products, services, tools, payment gateways, financial products, research services, insurance products, fixed deposit products, community platforms, social media platforms or other services.

64. Your access to or use of third-party services may be governed by the privacy policy, terms and conditions and consent mechanisms of the relevant third party. We do not control and are not responsible for the privacy practices, security standards, content, representations, products, services, actions or omissions of such third parties.

65. You should carefully review the privacy policy and terms of each third-party provider before providing information or availing any third-party service.

XII. Data Retention and Deletion

66. We retain Your information for as long as necessary for the purposes for which it was collected, including:

• a) providing the Platform and Services;
• b) maintaining Your account;
• c) complying with legal, regulatory, tax, accounting, audit and reporting obligations;
• d) resolving disputes and grievances;
• e) enforcing agreements and legal rights;
• f) preventing fraud, misuse and security incidents;
• g) maintaining transaction and payment records;
• h) complying with SEBI, RBI, IRDAI, payment, KYC and other regulatory requirements, where applicable; and
• i) legitimate business and operational requirements.

67. Notwithstanding any request for account deletion or deactivation, we may retain such Personal Data, records, logs, consent records, payment information, transaction records, KYC-related records, communications, complaints, grievance records and other information as may be required or permitted under Applicable Law, regulatory requirements, tax, audit, accounting, fraud prevention, cybersecurity, dispute resolution, contractual obligations or legitimate business purposes.

68. We may refuse, defer or restrict a request for account deletion where:

• a) any Service, subscription, transaction, payment, refund, chargeback, complaint, grievance, investigation or dispute is pending;
• b) retention is required pursuant to Applicable Law, any court order, regulatory direction or law enforcement request;
• c) the account is associated with suspected fraud, misuse, unlawful activity, unauthorised access, violation of our Terms or security incidents;
• d) deletion may prejudice our legal rights, regulatory obligations, audit requirements or ability to establish, exercise or defend legal claims; or
• e) You have outstanding payment obligations or other unresolved obligations towards us, our affiliates or our service providers.

69. We may retain certain information even after account deletion, subscription expiry, Service termination or withdrawal of Consent where retention is required or permitted under Applicable Law, contractual obligations, regulatory requirements, audit requirements, dispute-resolution requirements, fraud-prevention needs or legal claims.

70. Anonymised, aggregated or de-identified data may be retained and used indefinitely, provided it does not identify You.

XIII. Data Security

71. We implement reasonable security practices and procedures designed to protect Personal Data and Non-Personal Data from unauthorised access, collection, use, disclosure, alteration, loss, destruction or misuse. Such measures may include, as appropriate, access controls, encryption and other technical safeguards, secure authentication mechanisms, firewalls and monitoring tools, vendor due diligence, contractual confidentiality obligations, internal policies and access restrictions, incident response and business continuity procedures, periodic reviews of our security practices, and such other technical, organisational and administrative safeguards as We consider appropriate, having regard to the nature of the information processed and Applicable Law.

72. However, no method of transmission over the internet, mobile networks or electronic storage is completely secure. We cannot guarantee absolute security of information. You are responsible for maintaining confidentiality of Your login credentials, password, OTPs, device access and account activity.

73. You must immediately notify us at support@onepercentclub.io if You suspect unauthorised access, account compromise, security breach or misuse of Your account.

XIV. Your Responsibilities

74. You agree that:

• a) all information provided by You shall be true, accurate, current, complete and lawful;
• b) You shall promptly update Your information if it changes;
• c) You shall not provide false, misleading, fraudulent or third-party information without authorisation;
• d) You shall maintain confidentiality of Your login credentials and devices;
• e) You shall not share passwords, OTPs, payment credentials or account access with any person;
• f) You shall not upload unlawful, infringing, confidential, harmful or malicious content;
• g) You shall not input sensitive, confidential or regulated information into AI tools unless specifically required and permitted;
• h) You shall comply with Applicable Law and our Terms; and
• i) You shall be responsible for all activity undertaken through Your account, except where caused solely by our proven wilful misconduct.

XV. Children's Privacy

75. The Platform and Services are intended for persons who are competent to contract under Indian law, unless a specific Service is expressly made available to minors with lawful guardian consent.

76. We do not knowingly collect Personal Data from children without appropriate consent from a parent or lawful guardian where required under Applicable Law. If we become aware that Personal Data of a child has been collected without valid consent, we may take steps to delete or disable such information, subject to Applicable Law and legitimate retention requirements.

77. Where a parent or lawful guardian permits a child to access any Service, such parent or guardian shall be responsible for the child's use of the Platform and for providing valid consent where required.

78. We do not knowingly undertake tracking, behavioural monitoring or targeted advertising directed at children in violation of Applicable Law.

XVI. Marketing Communications and Opt-Out

79. We may send You promotional, educational, product-related, event-related, subscription-related or marketing communications through email, SMS, WhatsApp, telephone, push notification, in-app notification or other channels, in accordance with Applicable Law and Your preferences.

80. You may opt out of promotional communications by using the unsubscribe option, updating Your preferences, or contacting us at support@onepercentclub.io.

81. Even if You opt out of promotional communications, we may continue to send You essential communications, including account, payment, subscription, security, legal, regulatory, service, grievance and transaction-related communications.

XVII. Your Rights

82. Subject to Applicable Law, You may have the following rights in relation to Your Personal Data:

• a) Right to Access Information: You may request a summary of the Personal Data being processed by us and, where required under Applicable Law, obtain a copy of such Personal Data in a structured, commonly used and machine-readable format.
• b) Right to Correction: You may request correction of inaccurate or misleading Personal Data.
• c) Right to Completion: You may request completion of incomplete Personal Data.
• d) Right to Updating: You may request updating of outdated Personal Data.
• e) Right to Erasure: You may request erasure of Personal Data that is no longer necessary for the purpose for which it was processed, subject to legal, regulatory, contractual and legitimate retention requirements.
• f) Right to Withdraw Consent: You may withdraw Consent for processing, subject to the consequences and limitations described in this Privacy Policy.
• g) Right to Grievance Redressal: You may raise grievances regarding processing of Personal Data.
• h) Right to Nominate: Where applicable under the Digital Personal Data Protection Act, 2023, You may nominate another individual to exercise Your rights in the event of death or incapacity.

83. To exercise these rights, please contact us at support@onepercentclub.io. We may verify Your identity before acting on Your request.

84. You may request deactivation or deletion of Your account by writing to us at support@onepercentclub.io or through such account-deletion mechanism as may be made available on the Platform. Upon receipt of such request, we may verify Your identity before processing the request in accordance with Applicable Law, this Privacy Policy and our internal policies.

85. We may decline or limit requests where permitted under Applicable Law, including where compliance would violate law, affect rights of others, compromise security, prejudice legal claims, interfere with regulatory obligations, require disproportionate effort, or where retention is required by law.

XVIII. Grievance Redressal

86. If You have any grievance, concern or request regarding this Privacy Policy or the processing of Your Personal Data, You may contact our Grievance Officer/Data Protection contact at:

• a) Name: Ms. Preeti Tripathi
• b) Designation: Grievance Officer
• c) Email: support@onepercentclub.io
• d) Address: 601, Signature Suresh Sawant Road, Off. Veera Desai Road, Andheri (W), Mumbai – 400 053, Maharashtra, India
• e) Phone: +91-8655772112
• f) Working Hours: 10 AM to 6 PM

87. We will acknowledge and address grievances in accordance with Applicable Law. You agree to provide all information reasonably required to verify Your identity and resolve Your grievance.

88. For grievances relating to services provided by a third-party provider, regulated intermediary, bank, NBFC, insurer, payment provider, Research Analyst or other independent service provider, You may also be required to contact the relevant provider through its designated grievance-redressal mechanism.

XIX. Data Principal Duties

89. You acknowledge that under Applicable Law, including the Digital Personal Data Protection Act, 2023, You are expected to:

• a) comply with applicable laws while exercising Your rights;
• b) not impersonate another person;
• c) not suppress material information;
• d) provide only authentic information;
• e) not register false or frivolous grievances; and
• f) furnish information that is verifiably authentic when exercising Your rights.

XX. Anonymised and Aggregated Data

90. We may create, use, store, disclose, license, commercialise or otherwise process anonymised, aggregated, statistical, analytical or de-identified data derived from Your use of the Platform, provided such data does not identify You.

91. Such data may be used for analytics, research, product development, business intelligence, reporting, benchmarking, AI/tool improvement, security, marketing insights and other lawful business purposes.

XXI. User Content, Feedback and Testimonials

92. If You submit any content, comment, query, feedback, review, testimonial, image, video, assignment, response or other material on or through the Platform, we may collect, store, moderate, display, reproduce, publish, analyse or use such content in accordance with our Terms and this Privacy Policy.

93. You grant us a worldwide, royalty-free, perpetual, irrevocable, sublicensable and transferable right to use feedback, suggestions, ideas, testimonials, reviews, comments or recommendations provided by You for product improvement, marketing, business development, analytics, training, research and other lawful purposes, subject to Applicable Law.

94. Where we use Your name, photograph, likeness or identifiable testimonial for marketing, we will do so in accordance with Applicable Law and applicable consents.

XXII. Social Media and Public Forums

95. If You interact with us through social media platforms, public forums, community groups, webinars, live sessions, comment sections or third-party communication platforms, Your information may also be processed by the relevant platform according to its own privacy policy.

96. You should avoid sharing sensitive personal information, financial information, passwords, OTPs, investment details, confidential information or personal data of others in public or semi-public forums.

97. We may moderate, remove, report or restrict content that violates our Terms, this Privacy Policy, community guidelines, Applicable Law or third-party rights.

XXIII. Payment Security

98. Payments made through the Platform may be processed by authorised third-party payment gateways, payment aggregators, banks, card networks, UPI providers or other payment service providers.

99. Your payment information may be collected and processed by such providers in accordance with their own terms, privacy policies and security standards. We do not control their systems and are not responsible for their acts, omissions, downtime, failed payments, unauthorised transactions or data practices, except to the extent required under Applicable Law.

100. You should not share payment credentials, OTPs, PINs, passwords or banking credentials with any person, including anyone claiming to represent us.

XXIV. Regulatory and Financial-Service Records

101. Certain Services may require maintenance of records for regulatory, audit, compliance, investor-protection, grievance, dispute-resolution, tax or statutory purposes. Such records may include consent logs, access logs, disclosure acknowledgements, transaction records, risk acknowledgements, KYC records, product journey records, payment records and communication records.

102. We and/or the relevant affiliate or third-party service provider may retain and disclose such records in accordance with Applicable Law, including requirements prescribed by SEBI, RBI, IRDAI, tax authorities, courts, law enforcement agencies or other competent authorities. Such records may continue to be retained notwithstanding any account deletion request or withdrawal of consent, to the extent required under Applicable Law.

XXV. AI-Specific Data Handling

103. Where AI-powered tools, chatbot services or other automated features are made available through the Platform, We may collect, receive, store and process Your prompts, queries, commands, inputs, messages, files, content and AI-generated outputs for the purposes of providing, operating, maintaining, improving and securing such features.

104. We may also maintain logs of Your interactions for safety, audit, troubleshooting, fraud prevention, abuse detection, security, quality assurance, product improvement and other lawful purposes. AI-generated outputs are produced through automated processes and may not be reviewed by a human prior to being displayed. Accordingly, You should independently verify the accuracy, completeness and suitability of all AI-generated outputs before relying on them and should not treat such outputs as a substitute for professional, legal, financial, tax, investment, insurance, medical or other professional advice.

105. You should not submit any unlawful, confidential, sensitive, third-party proprietary, regulated or other information that You are not authorised to disclose through any AI-powered tool or chatbot, unless expressly permitted by Us for a lawful purpose.

106. We reserve the right to restrict, suspend or disable access to any AI-powered feature where We reasonably determine that its use involves misuse, abuse, unauthorised activity, legal or regulatory risk, security concerns or any other conduct that may adversely affect the Platform, the Services, Our users or any third party.

107. Where third-party AI service providers are used, information may be processed by such providers subject to contractual safeguards and Applicable Law.

XXVI. Do-Not-Track and Device Permissions

108. Certain Platform features may require device permissions, including access to notifications, camera, microphone, storage, contacts or location. We will request such permissions where required for a specific feature or functionality.

109. You may manage permissions through Your device settings. Disabling permissions may affect certain features.

110. The Platform may not respond to all “Do Not Track” signals due to lack of uniform technical standards.

XXVII. Business Transfer

111. In the event of any merger, acquisition, investment, financing, restructuring, reorganisation, business transfer, asset sale, slump sale, joint venture, insolvency, change in control or similar transaction, Your information may be transferred or disclosed as part of such transaction, subject to Applicable Law and reasonable confidentiality safeguards.

112. The transferee or successor entity may continue to process Your information in accordance with this Privacy Policy or a substantially similar privacy policy, unless otherwise notified.

XXVIII. Limitation of Liability

113. While we take reasonable measures to protect Your information, You acknowledge that no digital platform, internet transmission, mobile application, cloud storage system or electronic database can be guaranteed to be completely secure.

114. To the maximum extent permitted under Applicable Law, we shall not be liable for any indirect, incidental, special, consequential, punitive or exemplary damages, loss of profits, loss of business, loss of goodwill, loss of data, loss of opportunity, unauthorised access, cyberattack, third-party breach, service-provider failure, force majeure event or user negligence arising out of or relating to the processing of information, except to the extent such liability cannot be excluded under Applicable Law.

115. Nothing in this Privacy Policy limits any liability that cannot be excluded under Applicable Law.

XXIX. Changes to this Privacy Policy

116. We may amend, update, modify or revise this Privacy Policy from time to time to reflect changes in law, technology, business operations, Services, regulatory requirements or Platform features.

117. The updated Privacy Policy will be posted on the Platform with the “Last Updated” date. Where required under Applicable Law, we may notify You or seek fresh consent for material changes.

118. Your continued access to or use of the Platform after publication of the updated Privacy Policy shall constitute Your acceptance of the revised Privacy Policy, subject to Applicable Law.

XXX. Contact Us

119. For any questions, concerns, requests, grievances or communications regarding this Privacy Policy or our data-processing practices, please contact:

• a) One Club Ventures Private Limited
• b) Address: 601, Signature Suresh Sawant Road, Off. Veera Desai Road, Andheri (W), Mumbai – 400 053, Maharashtra, India
• c) Email: support@onepercentclub.io
• d) Phone: +91-8655772112
• e) Grievance Officer: Ms. Preeti Tripathi
• f) Grievance Email: support@onepercentclub.io

XXXI. Declaration

120. By accessing or using the Platform, You acknowledge and agree that:

• a) You have read and understood this Privacy Policy;
• b) You consent to the collection, use, processing, storage, disclosure, transfer and retention of Your information in accordance with this Privacy Policy;
• c) You understand that certain Services may not be available if required information or consent is not provided;
• d) You are responsible for ensuring that information submitted by You is accurate, complete and lawful; and
• e) You agree to be bound by this Privacy Policy, the Terms and Conditions and all applicable Service-specific terms, disclaimers and disclosures.