GENERAL

We are committed to keeping your data secure, your private information private, and being transparent about our practices. We adhere to the best practices to secure information collected from you.

At Bingo SG, we take privacy and security seriously. This Privacy Policy outlines how AIION GOLD , its parent entity Bingold Pte. Ltd. and its wholly owned subsidiaries including but not limited to Bingold Pte. Ltd. , AIION GOLD Private Limited (collectively, “AIION GOLD,” “we,” “our,” or “us” or “Company “) process the information that we collect about you through our websites, mobile apps, and other online services (collectively, the “Services”) and when you otherwise interact with us, such as through our customer care service channels. The Company owns, operates and manages a website having domain name AIIONGOLD and related software application for use on wireless computing devices such as smartphones and tablets and also for use on desktop or laptop computers under the name and style of “AIION GOLD” (collectively hereinafter referred to as “Platform” or “Application” ) .

The Platform facilitates and enables the User in availing certain online products and services from the Platform, including, inter alia, investment and wealth management services to the Users “Services” , in accordance with the terms and conditions of use/Service of the Platform, as available at (“Terms and Conditions”) .

For the purposes of this privacy policy (hereinafter referred to as "Privacy Policy" or “Policy”) , wherever the context so requires, references to the terms "User(s)" , "You" or "Your",shall mean and include the user, registered on the Platform, who uses or access the Platform or avails the Service(s) (as defined below) of the Platform in accordance with the Terms of Use.

This Privacy Policy is published in compliance with the Information Technology Act, 2000, and applicable amendments, rules, regulations and guidelines enacted thereunder from time to time (“IT Act”) with specific mention of regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive personal information) Rules, 2011, and any other national and state laws which relate the processing of data. This Privacy Policy is an electronic record in terms of the IT Act and this electronic record is generated by a computer system and does not require any physical or digital signatures. Any new features and/or services that are added to Our current service at any point in the future shall also be subject to the terms set out in this Policy along with any other future relevant legislations to be incorporated as per the laws of the land. This Privacy Policy shall apply to any person who visits, browses, uses or accesses the Platform or use any Services on the Platform.

This Privacy Policy, inter alia, states: (i) the type of information collected from the Users, including personal information and sensitive personal data or information (as defined below), relating to an individual; (ii) the purpose, means and modes of collection, usage, processing, retention and destruction of such information; (iii) how and to whom We will disclose such information; and (iv) how We will protect the Users’ personal information when they access the Platform.

AIION GOLD does not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to AIION GOLD. If AIION GOLD learns that we have collected personal information from a person under age 18, we will delete that information as quickly as possible. If you believe that a person under 18 may have provided us with personal information, please contact us at privacy @aiiongold.com, support@aiiongold.com


PURPOSE AND SCOPE OF PRIVACY POLICY

This Privacy Policy is published to inform and describe Our Users of Our policies and procedures regarding collection, storage, and processing and sharing of information that We receive from our Users on the Platform or those which are stored or accessed by Us at the time of availing/ registering for the Services or making transactions on the Platform. We have developed this Policy to familiarize You with Our practices and demonstrate Our commitment to the protection of Your privacy and your personal information. With regard to this Privacy Policy, the terms "using”, and "processing" information include, without limitation; the use of cookies; and the collection, storage, transfer, evaluation, deletion, disclosure, management, handling, modifying and use of information.

You hereby consent to Us collecting, using and sharing and disclosing Your information as described in this Privacy Policy. If You do not agree with this Privacy Policy at any time, time, please do not use any of the services, use or access the Platform or give Us any of Your information

COLLECTION OF PERSONAL DATA

In order to enable a User to have access to the features, benefits or use of the Services on Our Platform, the User may require to provide certain information on the Platform which may constitute ‘personal information’ or ‘sensitive personal data or information’ of a person which shall be governed under regulation 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive personal information) Rules, 2011 , along with other relevant data privacy laws of the land and Prevention of Money Laundering Act (PMLA) 2002.

ON BOARDING/ REGISTRATION OF SERVICES:

    When You create a new account to use the Services we request for the following information:
  • ✓ Name, DOB, Gender, Nationality, Father’s name, Mother’s name, Marital status, photo;
  • ✓ Address, ZIP/postal code, location, phone number, e-mail id, your contacts and nominee details;
  • ✓ Bank account number, your name on bank passbook and IFSC code of the bank;
  • ✓ PAN card number, Aadhar card number(redacted), KYC related information either through videos or other online/ offline verification documents as mandated by relevant regulatory authorities, for the services you shall be utilizing (purpose of investments & transactions) and your business-related information.
  • ✓ Employment related details (e.g., occupation, income, employer details, designation) as part of our record retention for Central KYC Records Registry (CKYCR) purposes under Prevention of Money Laundering (Maintenance of Records) Rules, 2005
  • ✓ Information in relation to Your device by way of using our app like, communication information including contacts and call logs, device information (including storage, model, mobile network), browser plug-ins, and cookies or similar technologies that may identify your browser Application and plug-ins, notifications etc.

KYC DETAILS:

  • ✓ To comply with regulatory requirements, based on Your explicit consent we fetch Your KYC (Know Your Customer) details from regulated Central KYC Registry

LIABILITIES INFORMATION

    You provide an explicit consent to Us for the following:
  • ✓ collect credit related information from third party service provider that are expressly authorised by You to distribute such information (for example, Experian or CRIF High Mark which is a credit information company registered under the Credit Information Companies (Regulation) Act, 2005).
  • ✓ We shall securely store account details for each of your Bank accounts or Paypal account, including your sign-in username and authorisation tokens for tracked accounts. This information will be used to enable Us to automatically access Your applicable details to analyze, extract, and store information securely from such accounts for use in the Application

GOOGLE ACCOUNT EMAILS (GMAIL):

  • The User may also choose to provide explicit consent to connect/integrate the User’s Gmail account(s) with his/her account on the Platform. You will be expressly asked in each case particularly, whether You want to connect Your email address with Your account on the Platform. You can also choose to enable Our access to one or more of Your email accounts by connecting such account(s) with Your account on the Platform. The following are the information collected from Your consented email accounts:
  • ✓ The attachments from the senders who have the details of your investments such as Folio numbers, Transaction Dates, Dividends, Subscription and Redemption Amounts. AIION GOLD organizes this information in your account to provide deep analytics and other services.
  • ✓ We access your Gmail account and seek your explicit consent in auto sending the information related to the commission and profit you earn on AIION GOLD Platform. You can choose to provide explicit consent to connect your Gmail account with AIION GOLD account (using Google’s OAuth authentication method). Basis your permission, we “read only” the attachment to facilitate you in organizing your financial life effectively .
  • ✓ The benefit of opting to connect Your Gmail account is that your both investment and expense information gets updated automatically every month. Given the updated information, the application can hence give you deep and accurate analytics on your net worth.
  • ✓ You can choose to de-link your Gmail account with the application at any time and/ or you can delete your information by writing to privacy@AIION GOLD.com, support@AIION GOLD.com
  • ✓ Please note that such data obtained by this integration will be used by the Company solely for providing the Services, updating the User’s investment information on a monthly/ quarterly / annual basis, providing accurate analytics on the User’s investments and further improving the User experience pertaining to the features of the Platform. We shall not use or transfer any data or information received from the integration of the email addresses with the account on the Platform to third parties for any purpose other than as explicitly authorised by the User.
  • ✓ We encourage the User to review the information prior to giving consent for integration of the email address with the account on the Platform. The User may at any time opt to de-link the email address connected with the account opened on the Platform and/or delete the information by writing to privacy@AIION GOLD.com/ support@AIION GOLD.com.
PROCESSING OF PERSONAL INFORMATION

We may process your personal information collected from You for, including without limitation, the following purposes:

Components

    Reason for processing the Data

Services opted in Platform (investments, deposits, transactions etc)

  • to facilitate Your requests with respect to Our varied range of financial plans and services offered by Us. For example, personal information is processed in order to organize and aggregate the User’s financial information in one place on the Platform, facilitate the Platform to provide the User analytics on their investments, liabilities & expenses, help the User to assess their risk profile from time to time, create the User’s investment plans and make decisions on investments.

Value Added services

  • to provide information to our Affiliate companies and its authorised agents and other third-party services providers so far as required for providing information about products/services of our Affiliate companies and / or to offer similar services and to provide you with various value-added services and information including for authentication purposes to enable linking of Your plan held with Us.

KYC compliance

  • to conduct the KYC compliance process as a mandatory prerequisite as per the requirements of various regulatory bodies, to validate, process and/or share Your KYC details, nominee details with other intermediaries, Regulated Entities or financial institutions or with any other service providers as may be required;

Sharing /Communication

  • by sharing the information, You are allowed to contact either through Us or our third-party service providers through any channel of communication including but not limited to email, telephone, sms, etc.

Alerts/ notices

  • to intimate and deliver You any administrative notices, alerts, advice and communications relevant to Your use of the Service;
  • to send You important notices and communications regarding Our services availed or changes to the terms and conditions and/or policies, to administer Our business and Platform;

Customisation of platform/ offers

  • to customize the content of Our Platform, request You for reviews of the Services; send You verification message(s) or email(s) validate/authenticate Your account and to prevent any misuse or abuse,
  • to contact You on Your birthday and/or anniversary to inform You of any special offers if any available;

Compliance with applicable laws

  • to deal with enquiries and complaints raised by You and to troubleshoot problems, ensure compliance with all applicable laws and to ensure safety of the Platform and all Users, to prevent fraud, errors and/or any illegal activity on the Platform, for conducting audits and for record keeping purposes


DISCLOSURE OF DATA

It may be necessary for Us to disclose Your personal information whether by law, legal process and/or by request from public and/or governmental authorities within or outside of your country of residence. We may also disclose Your personal information if We determine that disclosure is necessary or appropriate for the purposes of law enforcement, national security or to prevent or stop any activity We may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.

You agree that in addition to as may be provided in this Policy, We may also disclose Your personal information under the following circumstances:

Third party service professionals and/or providers: : We engage, retain or might, as per requirement and business needs of the Company, employ, engage, contract with third party service professionals/providers to work on behalf of or with Us, under agreements containing confidentiality obligations and in accordance with law, in relation to the services provided by Us on the Platform. These third-party service providers may use Your personal information in assisting Us to communicate with You about Our offers, feedback of Services, assisting in payment facilities, providing customer support, assisting in advertising on the Platform etc. We may employ third party companies and/or individuals to help improve or facilitate our service, to provide the Service on our behalf, to perform platform-related services, including but not limited to: payment processing, maintenance services, fraud detection services, database management, web analytics, monitoring, delivery/logistics and evaluation services. In this event, your information may be shared with such third-party companies and/or individuals;

Compliance with laws and protection of Users:We may release your personal information when the same is required in order to comply with the law, in response to court orders, court summons, judgments, decrees, injunctions, arbitral awards, administrative orders, governmental investigation or orders of any government authority or any other legal process, to establish/exercise Our legal rights or defend against legal claims or in the event We reasonably believe that doing so is legally required or is in your interest to protect Your property or other legal rights or property or rights of others. We may also share your personal information in order to enforce and fully comply with Our terms of service and other Company policies;

Business transfer and mergers:We may transfer Your personal information if the Company, is acquired by or merged with another Company, to the extent permitted by applicable law and/or required under the scheme/arrangement of merger, etc. In such an event We will notify You before Your personal information is transferred/shared with the other entity and hence becomes subject to a different Privacy Policy;

Contracting parties:We transfer/share Your information with Our service professionals, group companies or business partners to facilitate the availing/provision of Services by You.

With Your consent in addition to the aforementioned circumstances, we may share Your personal information with third parties with Your prior consent and/or at Your request if necessary, at future course of time.

COLLECTION AND USE OF NON-PERSONAL DATA

Non-personal data is data that can never be used to identify an individual. We may collect information regarding customer activities on Our Platform. This aggregated information shall be used by Us in research, analysis, to improve and monitor Our services and for various promotional schemes and offers. Such non personal data may be shared in aggregated, non-personal form with third party to enhance customer experience, offerings or services. The Platform uses cookies, and while using the Platform You will be prompted to accept all cookies. We may place text files in the browser files of Your computer system.

COOKIES POLICY

A cookie itself does not contain personal information and it will only enable Us to relate Your use of the Platform and Your behaviour on the Platform to information that You have specifically and knowingly provided. The only personal information that a cookie can contain is the information You supply to the cookie. A cookie can’t read data off Your hard disk or read cookie files created by other websites.

We may place both permanent and temporary cookies. A permanent cookie will remain on Your web browser until its expiry date, unless deleted prior to such expiry date. However, most cookies are “session cookies” meaning that they automatically get deleted from your computer system at the end of the session. You can refuse cookies by turning them off in Your browser or alternatively You can also set your browser to warn You before accepting any cookies. Therefore, You are always free to decline Our cookies if Your browser permits, however We use certain cookies to authenticate Users on each page after the User logs on to the Platform or accesses any Services. If you, as a casual visitor, have inadvertently browsed any other page of this Platform prior to reading this Privacy Policy, and you do not agree with the manner in which such information is obtained, collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by Us. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as We cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Platform. Please note that You are not a casual visitor if you have willingly submitted any personal information or information to Us through any means, including email, post or through the registration process on the Platform. All such visitors will be deemed to be, and will be treated as Users for the purposes of this Privacy Policy, and in which case, this Privacy Policy applies in its entirety to such persons.

The data that cookies collect will be used to process and/or analyse information by third parties to help improve or facilitate Our services, to provide Service on Our behalf, to Platform-related services, including but not limited to; maintenance services; fraud detection services; database management; web analytics; monitoring; and evaluation services. If you have any questions about Our cookie usage, please contact Us at the contact details/information mentioned below.

YOUR RIGHTS AND HOW TO EXERCISE THEM

We respect the exercise of the rights You have in relation to the personal data and information We process or use. You can request access to or a copy of your personal and information collected and processed by Us. You may also request the rectification and removal of personal data and information or the restriction of the processing of Your personal data and information. Users have the right to unilaterally change their e-mail and contact preferences at any time by logging into their "Account" on the Platform and changing the account settings. You also have the right to data portability. If You have an objection to use of Your data under this Policy, please write to Our privacy team at contact information given below. To prevent misuse, we will ask You to identify yourself.

DISCLAIMER OF INFORMATION

We respect the exercise of the rights You have in relation to the personal data and information We process or use. You can request access to or a copy of your personal and information collected and processed by Us. You may also request the rectification and removal of personal data and information or the restriction of the processing of Your personal data and information. Users have the right to unilaterally change their e-mail and contact preferences at any time by logging into their "Account" on the Platform and changing the account settings. You also have the right to data portability. If You have an objection to use of Your data under this Policy, please write to Our privacy team at contact information given below. To prevent misuse, We will ask You to identify yourself.

You are responsible for maintaining the accuracy, truthfulness, correctness and completeness of the information You submit or provide to Us, on the Platform; and shall hold harmless and indemnify Us from and against all claims arising out of or in relation to the wrongful information posted, provided by You to Us, on the Platform. If Your personal information changes, You may correct, delete inaccuracies, or amend information by making the change on Our member information page or by contacting Us on the contact information given below. There may be circumstances where We will not correct, delete or update Your personal data information, including; (i) where the personal data and information is opinion data that is kept solely for evaluative purpose; and (ii) the personal data information is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed. If you wish to cancel your account or request that We no longer use your information to provide you Services, you may contact us on the contact information given below.

SECURITY

We understand the serious implications of data security and take extensive measures to ensure Your data and information is secured. We take extensive technical and legal measures to safeguard Your personal data and information.


COMPLIANCES

We are an ISO certified company and have implemented required Information Systems Management System policies and procedures in order to maintain industry standard best practices and applicable controls as necessary for protecting the data of Our Users.

AIION GOLD's use of information received from Google APIs will adhere to Google API Services User Data Policy , including the requirements as necessary to the extent of adhering to the scope and policy.

We will also be undergoing annual security assessment from a Google-designated third party and keep the same updated from time to time or as per instructions from Google and will publish the “letter of assessment” on AIION GOLD website and mobile applications.

RETENTION PERIOD

We do not keep your personal data and information longer than necessary for the purpose of the processing except for any record retention required by applicable laws, including but not limited to Securities and Exchange Board of India (Investment Advisers) Regulations 2013, Insurance Regulatory Development Authority of India (Registration of Corporate Agents) Regulations 2015 and Prevention of Money Laundering Act 2002. This includes, for example, the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to carry out legal work, for the establishment or defence of legal claims. We may aggregate and anonymize your personal data and information (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

CHANGES IN PRIVACY POLICY

We reserve the right to change the Policy at any time. You may note that this Policy itself and any such change of policy will be effective from the date of posting on the site.

Any changes shall be effective immediately upon the posting of the revised Privacy Policy. While We will make reasonable efforts to keep You posted on any updates to this privacy policy, to make sure that You are aware of any changes, We recommend that You review this policy periodically. If You are not comfortable with any of the changes to Privacy Policy, You may choose to discontinue usage of AIION GOLD website or mobile applications. You can also email us at privacy@AIIONGOLD.com, support@AIIONGOLD.com to update or delete Your personal information that AIION GOLD has collected.

QUESTIONS OR COMPLAINTS

If you have any question or complaints about the processing of your personal information, write to us at privacy@AIION GOLD.com, support@AIION GOLD.com. Our team will be happy to assist you.

CONTACT INFORMATION

Address: #10-06, textile Center, Singapore

Email: privacy@AIION GOLD.com and support@AIION GOLD.com

GRIEVANCE OFFICER

In accordance with the provisions of the Information Technology Act, 2000, and rules made thereunder, the name and contact details of the Grievance Officer are provided below:

Attn: Mr.

Designation: Grievance Officer

Email: grievance@AIION GOLD.com

Time: Mon - Friday (10 AM - 7 PM)

Address: #10-06, textile Center, Singapore