Privacy Policy - Together Innovation Labs Pvt. Ltd.
Mindful Innovation Labs Private Limited, a company incorporated under the Companies Act, 2013 and having its registered office at L-148, 5th Main Road, Sector 6, HSR Layout, Bangalore , Bangalore, Karnataka, India, 560102  (hereinafter referred to as " We " , " Us " and “Crypso” and shall include any affiliates) understands the position We are in while providing the services through our website https://crypso.club/ and mobile application under the brand name ‘Crypso’ (collectively referred to as “Platform”) and are committed to protecting the information and data shared by all of our users (hereinafter referred to as “You”, and “User”). In light of the same, we have created this privacy policy (“Privacy Policy”) which is in compliance with the Information Technology Act, 2000 (“IT Act”), Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the " SPI Rules " ) and Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
The privacy mechanism outlined in this Privacy Policy, as amended from time to time, identify personal information or sensitive personal information (collectively “Personal Information”) that may be collected, how such information is used, and the choices You have regarding our use of such information. For the purpose of this Privacy Policy, the terms ‘personal information’ and ‘sensitive personal information’ shall have the meaning as ascribed to them under the SPI Rules.
Please read this Privacy Policy carefully as by accessing or using the Platform, You agree to be bound by the terms described herein and all the terms incorporated by reference. Any information provided to Us is subject to this Privacy Policy. If You do not agree to any or all of the terms contained herein, do not use the Platform. Should You continue to access and use the Platform and provide your Personal Information, such act would constitute your consent to the terms contained herein.
All capitalized terms shall have the meaning ascribed to them in the Terms and Conditions unless otherwise defined herein.
  1. Your Consent
    1. A prerequisite for obtaining access to the Platform and usage of the services provided on the Platform is the acceptance of this Privacy Policy. This Privacy Policy shall apply to all individuals that use the Platform. You grant your consent to be bound by the terms of this Privacy Policy by:
      1. accessing the Platform or registering on the Platform in the manner as provided for in the Terms & Conditions;
      2. submitting any information to Crypso while creating your Account, Wallet, KYC verification process, undertaking transactions through the Platform, uploading or posting User Content or otherwise through electronic communication or other communication with Crypso
      3. using the features and services offered by Crypso on the Platform
    2. As part of providing our services to You, We may need to send routine communications to You, such as order transaction emails and other administrative messages through email and notifications posted on the Platform or through other means available, including SMS and other forms of messaging. Though We prefer to communicate with the users via email and SMS, as may be deemed necessary, You agree to receive our phone calls or any other mode of communication as may be deemed appropriate.
    3. When You register with the Platform or otherwise access the Platform You also consent to allowing Us to periodically send emails about information, which You may find interesting and in line with your interests. If You do not wish to receive promotional information from Us, You can, at any time, choose to opt out of receiving such promotional communications by following the process mentioned in the promotional communication.
    4. You must ensure to provide Us with the correct or up-to-date information at the time of creation of your Account, Wallet and during the use of the Platform. This will allow Us to contact you for further correspondences with respect to the services provided on the Platform. We are not responsible for any inaccurate information You provide to Us, which may affect your experience when using the Platform and the services.
    5. If, at any time, You want to access, update, modify or eliminate any information provided by You or which forms a part of the Account/Wallet created with Crypso, You may do so by accessing your account and then changing your information as required. You may also withdraw your consent for use of your Personal Information provided and stop using the services for which consent is required. Crypso reserves the right to stop providing any services to which consent has been withdrawn.
    6. We may, in future, request other optional information from You in order to customise the Platform to deliver personalised service to our users.
  2. Personal Information
    1. While availing our services on the Platform You may provide Crypso with certain Personal Information which are required for performance of the services on the Platform. Any data that is freely available to the public or made available to Crypso through public sources or by way of right to information will not be considered as Personal Information. We do not knowingly collect Personal Information from children, and all information upload by a User shall be deemed to be uploaded in compliance of all applicable laws.
    2. Crypso has implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of our business. While We try our best to provide security that is commensurate with the industry standards, because of the inherent vulnerabilities of the internet, We cannot ensure or warrant complete security of all Personal Information that is being transmitted to Us by You. However, Crypso will take all reasonable measures to ensure that your Personal Information is not modified or used for any unauthorised purposes.
    3. You have the right to access your Account with Crypso and edit, modify or delete any Personal Information provided to Crypso. When editing or deleting Personal Information shared by You at your request, We may ask you to verify your identity before We can act on your request. However, We do not assure that We will delete all residual copies and archives made by any third party service providers for performance of their obligations.
    4. During the course of provision of services or registration and creation of your Account, the following Personal Information may be collected from the Users (collectively “Account Data”):
      1. Name
      2. Gender
      3. Age
      4. Nationality
      5. Email address
      6. Mobile number
      7. Address (including country and ZIP/postal code)
      8. Other details as Crypso may deem necessary for provisioning services or required under applicable laws.
    5. Crypso may keep records of telephone calls received and made to their personnel for provision of the services or for making inquiries, orders, or other reasons for the purpose of administration of services. Crypso may further keep records of all chats, conversations and information shared on the Platform by the User for the purpose of administration of the services.
    6. During the use of the Platform via the internet, We may automatically receive technical information about your computer/device, including your IP address, your computer operating system, time-zone, browser type and browser plug-in details, due to the communication protocol settings on the Internet. When You browse our Platform, We may also collect information regarding the pages You viewed, the web addresses from which You arrive or click through to, time spent on certain pages, download errors and page response times. All these information help Us analyse user ' s trends and preferences, and thus assist us in improving our services.
    7. The Platform enables Users to communicate with other Users through the forums created by Users on the Platform, whereupon other Users may collect such data. Crypso hereby expressly disclaims any liability for any misuse of such information that is made available by Users in such a manner.
    8. Crypso may include other optional requests for information from the Users with a view to customize the Platform to deliver personalized information to the User and for other purposes as mentioned in this Privacy Policy. We may receive and process information about your location. Any such additional Personal Information will also be processed in accordance with this Privacy Policy.
    9. Crypso shall not be responsible in any manner for the authenticity of the Personal Information supplied by the User to Crypso. If a User provides any Personal Information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or Crypso has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, Crypso has the right to suspend or terminate your Account at its sole discretion.
    10. Crypso engages certain trusted third parties to perform functions and provide services. You hereby consent to your Personal Information to be shared with these third parties. Crypso shall ensure that these third party who have been given such Personal Information shall only use the data for the specific purposes for which the Personal Information is provided and Personal Information is only shared pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your Personal Information.
    11. From time to time, Crypso may also obtain your Personal Information from third party sources as required or permitted by applicable law.
  3. Use of Personal Information
    1. Crypso collects and retains your Personal Information only to the extent that it is necessary to render our Services to You and for regulatory purposes. Any Personal Information submitted by You on the Platform or collected by Us will be used only for the purposes mentioned below:
      1. for registration of the User on the Platform.
      2. to carry out our obligations arising from your requests for Services on the Platform.
      3. to improve the Platform ' s functionality, and to customise your future experience with Us.
      4. to generate and publish any details of your portfolio, transactions or trades with the Trading Platform by way of signals or other features available on the Platform (which may be controlled or restricted by you through your ‘privacy settings’ available under “privacy preference” section in the mobile app
      5. to make sure that our Platform’s Content is presented in the manner that is most effective for You.
      6. to monitor and remove, where required, User Content posted or uploaded on the Platform.
      7. to deliver personalized information and target advertisements to the User.
      8. for conducting research on efficient administrative practices on the Platform.
      9. to communicate with You about any changes to our Services.
      10. for registration and linking of your account with the trading interface/screen available through the mobile application called ‘Crypso’ and operated by Mindful Innovation Labs Private Limited (“Trading Platform”).
      11. Non-personally identifiable information, exclusively owned by Crypso may be used in an aggregated or non-personally identifiable form for internal research, statistical analysis and business intelligence purposes including those for the purposes of determining the number of visitors and transactional details, and Crypso may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates.
      12. addressing grievances, complaints and queries raised by the Users and take appropriate action against the same.
      13. ensuring that the provisions of the Terms & Conditions and Privacy Policy are complied with by all Users.
    2. We may share information about You with your consent or at your direction.
  4. Disclosure of Personal Information
    1. Crypso in the course of performance of the services may need to disclose/ transfer certain Personal Information to third parties for the purposes mentioned in this Privacy Policy and the Terms & Conditions. The third parties to whom such information may be disclosed include:
      1. Affiliates, subsidiaries, related party or member of group companies as may be necessary to achieve the purposes set out in clause 3 above and who may use and disclose your Personal Information for the same purposes as Us.
      2. Specifically to Mindful Innovation Labs Private Limited, for the purposes of and in relation to your account with the Trading Platform.
      3. Service providers as may be necessary to achieve the purposes set out in clause 3 above.
      4. To our employees, agents, consultants and professional advisors for the purpose of ensuring provision of services on the Platform, subject to the fact that our employees, agents, consultants and professional advisors shall be bound by obligations of confidentiality.
      5. To government institutions/ authorities to the extent required i) under the laws, rules, and regulations and/ or under orders of any relevant judicial or quasi-judicial authority; ii) for the purposes of prevention, investigation and prosecution of cyber incidents; iii) for reporting any offences committed by User; iv) to protect and defend the rights or property of Crypso; v) to enforce Terms & Conditions (to which this Privacy Policy is also a part); vi) for verification of any information provided by Users; or vii) when Crypso, in its sole discretion, deems it necessary in order to protect its rights or the rights of others.
      6. We may share information to prevent imminent and serious harm to a person.
      7. To third party ad servers, ad agencies, technology vendors and research firms to serve advertisements to the User.
      8. Where substantially all our assets are acquired by a third party, Personal Information may be one of the assets that is transferred or acquired by a third party. Under such circumstances, Crypso would attempt to ensure that the third party acquiring Crypso follows the provisions of this Privacy Policy and process your Personal Information as set forth in this Privacy Policy.
  5. Duration for Retaining Personal Information
    1. Under normal circumstances the Personal Information collected by Crypso will only be retained for such periods of time as may be required for the provision of Services. We may retain the other information throughout your use of the Platform and for a period of five (5) years thereafter or such other period as may be prescribed by applicable laws. Confidentiality of such information shall be maintained during the period of retention.
    2. 2. Crypso may be required to retain Personal Information in relation to the Users for records which may be required to be submitted to the appropriate authorities as and when required. Crypso shall keep confidential all information retained for such record keeping purposes.
    3. Upon deletion of Your Account, we shall retain Your information period as prescribed under law, to ensure compliance with our legal requirements, applicable laws and/or to comply with any requisition / requests from any legal, regulatory, statutory or other authority.
  6. Security Policy
    1. Crypso takes careful precaution to protect our Users’ Personal Information from unauthorised access, improper use or disclosure or unauthorised modification. To prevent unauthorised access, We have put in place the latest industry-standard security technology and procedures to safeguard the Personal Information We collect online including technical, operational and physical security controls. Your Personal Information is encrypted and is protected with the most secure encryption software, which encrypts all information You input. We store your Personal Information on the computer servers placed in a secure environment. Crypso also ensures that all third party service providers to whom Personal Information is provided take similar precautions with the information. Even though We have taken significant steps to protect your Personal Information, We, including the Platform cannot fully eliminate security risks associated with Personal information. We further disclaim any responsibility for any intercepted information sent via the internet, and You hereby release Us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.
  7. Third Party Links
    The links to third-party advertisements, third party websites or any third party electronic communication services (referred to as “Third Party Links”) may be provided on the Platform which are operated by third parties and are not controlled by, or affiliated to, or associated with Crypso unless expressly specified on the Platform. If you access any such Third Party Links, We request You review the website’s privacy policy. We are not responsible for the policies or practices of Third Party Links.
    1. Cookies
      The Platform uses temporary cookies to store certain data (that is not Personal Information) that is used by Us for maintenance of the Platform and its features as well as research and development, and for administration of your Account and Wallet. In the course of serving advertisements or optimizing services, We may allow authorized third parties to place or recognize a unique cookie on the your browser. We do not store Personal Information in the cookies.
    2. Amendment to Privacy Policy
      1. Crypso may update or amend this Privacy Policy at any time, with or without advance notice to You. In the event there are significant changes in the way Crypso treats the User ' s Personal Information, Crypso will display a notice on the Platform or send User’s an email.
      2. Notwithstanding the above, Crypso shall not be required to notify the Users of any changes made to the Privacy Policy except sharing a privacy police once a year with all the amendments for the perusal of the Users. Should You have any concern or reject the changes in the Privacy Policy You can refuse to accept the amendments and opt for withdrawing your Personal Information by writing to the Grievance Officer.
    3. Grievance Officer
      If You have any compliant or grievances or concerns with respect to Platform or this Privacy Policy, please inform such matters to the designated Grievance Officer as mentioned below in writing or through electronic mail:

      Name: Abhijeet Vyas
      Email Address: support@crypso.club
      Designation: Grievance Officer