1. Introduction

Elite Wealth Limited (Elite Wealth) as mentioned in this privacy policy is concerned about the privacy of the data and information of the users accessing and availing services on any of Elite Wealth websites including without limitation ‘www.elitewealth.in’, mobile sites, mobile applications or chrome extension or plugins thereof accessible through various internet enabled smart devices (individually and collectively referred to as “Platform”) or otherwise doing business with Elite Wealth. This Privacy Policy applies to Elite Wealth and helps you understand how we collect, use, store, process, transfer, share and otherwise deal with and protect all your information when you visit any of our Platform and avail our services or even otherwise visit the Platform.

This privacy policy is an electronic record in the form of electronic contract in terms of Indian Information Technology Act, 2000 And Rules made thereunder mended from time to time) and does not require any physical signature or seal.

The term “We”/ “Us” / “Our” used in this document refer to Elite Wealth and “You” / “Your” / “Yourself” refer to the users, who visit or access or use (collectively “usage”) Platform.

2. Purpose

When it comes to Customer and Partner data privacy, a privacy policy is a key legal document which describes your company’s data processing practices. Privacy Policies serve a few specific purposes:

▪ Privacy Policies compel businesses to act more transparently.
▪ A Privacy Policy gives individual website users and consumers more control over their personal information.
▪ Privacy Policies can help build trust between website owners and consumers because both parties know what is expected of them Privacy Policies strike a balance between the rights of individuals to control who they share data with, and the need for businesses to process some personal information for commercial purposes. Therefore, the privacy policy is a document that discloses what types of information you collect from your users and why. It also describes the methods you use to collect personal data e.g. cookies and how people can limit the data they share with Elite Wealth Limited (Elite Wealth) and ensure compliance with laws and regulations applicable.

3. Scope

This policy governs all personal information collected by and provided to us and must be adhered to by all people who access, use, process, control or otherwise deal with personal information on our behalf. This policy applies to independent contractors and job applicants, as well as individuals who provide us with personal information.

4. Policy Covered
This policy is designed to make you understand:
▪ The type of information which you share with us or which we collect during your usage of our platform or availing any Services from Our Platform.
▪ The purpose of collection, storage, processing and transferring of your Information by Us.
▪ Security measures implemented by us to protect your Information as mandated by law.
▪ Disclosure, sharing and transferring your personal information by us and purpose of such disclosure, sharing or transfer.
Controller of Personal Information

Elite Wealth Limited (Elite Wealth) will be the controller of your Personal Information provided by you or otherwise collected by us. Your data controller is responsible for the collection, use, disclosure,retention, and protection of your Personal Information in accordance with its privacy standards as well as any applicable laws.

Information We Collect (Your Information):

We collect Your information during Your usage of Platform or when You avail any services available on or through Platform, either as a registered user or otherwise when you visit any other website pages or other mobile applications. The information collected may consist of

▪ Your Personal Information:

Your full name, age, address, email id, phone number, date of birth, gender, financial information, any other sensitive personal data or information etc. We collect Your Personal Information when You create an account at Our Platform or fill out a form or respond to a survey.

▪ Your non-personal information:
1. Usage:

How You use Our Platform, such as the types of content that you view or engage with, the features You use, Your searches & results, Your browsing information, the actions You take and the time, frequency and duration of your activities.

2. Device Information:

Information about the computer, mobile, laptop, tablet or any other internet enabled electronic device (‘Device”) You use to access the Platform. This may include real-time information about the geographic location of Your Device as permitted by You, internet connection, Your IP address, operating systems, platforms, browsing information, Device type, Device ID, network information, meta data and other information associated with other files stored on Your Device, last URL visited, your website search history.

3. Preference:

Your preferences and setting such as geographical location, time zone and language.

4. Information from third parties:

We may collect, process and store Your user ID associated with any social media account (such as your Facebook and Google account) that You use to sign into the Platform or connect with or use with the services. When You sign in to Your account with Your social media account information, or otherwise connect to Your social media account with the Services, You consent to Our collection, storage, and use, in accordance with this Privacy Policy, of the information that You make available to Us through the social media interface. This could include, without limitation, any information that You have made public through Your social media account, information that the social media service shares with Us, or information that is disclosed during the sign-in process. Please see Your social media provider’s privacy policy and help center

5. Information about Your transactions with us, or previous insurers, such as Your policy coverage, claim information, premium and payment history.
6. Other information as may be required by the insurance companies or provided by You on insurance applications or questionnaire.
7. Cookies and other Electronic Tools:

We may use cookies, pixel tags, web beacons, mobile device IDs, “flash cookies” and similar files or technologies to collect and store information in respect to Your use of the Platform.

You can erase or choose to disable/block these cookies through Your Device/browser settings. You can configure Your browser to alert You when we attempt to send You a
cookie with an option to accept or refuse the cookie. If You have turned cookies off, You may be prevented from using certain features of the Platform and this may interfere with certain functionality of the Platform.

8. Browser Add-on/Extension:

Add-on or Extensions are software programs that can modify and/or enhance the functionality of browsers. You can add extensions to your browser (Chrome, Firefox etc.) for a more personalized experience. Add-on / Extension can access Your data on all the websites You visit, the tabs and the browsing activity of the browser. Add-on / Extension is stored locally to provide a better user experience for You. We would capture Your email address so as to notify You with relevant information. We would also capture other details to provide You a better user experience. When You add Us to Google Chrome as Chrome Extension, You explicitly permit Us as well as third parties, to the extent apply, to display notifications, read and change Your browsing history, read and change Your bookmarks,manage Your apps, extensions and themes, detect Your physical locations, read all Your data
on the website and other changes.

5. Communication

We may contact You through email, mobile phone, notices posted on Our Platform and other ways including but not limited to text messages and push notifications or any other mode. We may send You messages or emails about the availability of Our services, notifications, promotional messages, security, or other service-related issues. You hereby override your NDNC registration. You may change Your communication preferences at any time.

6. Manner of storage of Your Information

Your Information will mostly be stored in electronic form however certain data may be stored in physical form. We shall store, collect, use and process Your Information within Republic of India subject to compliance under applicable laws. We may enter into agreements with third parties within India to store or process Your Information and such third parties may have their
own security measures to safeguard Your Information which security standards as comparable with good industry practices

7. Purpose of Collection, Storage, Processing of Your Information
Elite Wealth collect Your Information solely for the purpose of providing you the services that is connected with the function or activity of the Elite Wealth which includes but not limited to the
following (“Purpose”):
▪ To inform You about various insurance products and services offered on Our Platform and provide customer support to You.
▪ To address Your queries and resolve your concerns pertaining to any insurance product or service that You were looking for.
▪ To send facilitate various programmes and initiatives launched either by Us or third party which We believe may be of interest to You.
▪ To facilitate Your usage of Platform (what features You like, how You use the, etc.) and improve Our services, or any other content on the Platform (such as by personalizing content to your interests), process and complete your transactions, and make special offers.
▪ To review Platform performance, diagnose technical problems and do data analysis to make Your experience better.
▪ To protect the integrity of Our Platform.
▪ To inform You about change in any term and condition of this Privacy Policy or Terms of Use of any Platform of Elite Wealth.

To implement information security practices, to determine any security breaches,contaminant or computer virus, to investigate/prevent/take action against illegal activities and suspected fraud.

▪ To keep You informed about news, events and ideas regarding Your preferences and help You to improve Your knowledge and skills about the preferred content.
▪ To carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us.
▪ To allow You to participate in interactive features offered through Our Platform.
▪ To contact You about Our services that may be of interest to You. If You do not want Us to
use Your Information in this way, please adjust Your user preferences in Your account
profile.
▪ To produce and share aggregate insights and statistics that do not identify You..
▪ For any other purpose with Your consent.
8. Sharing, Transfer or Disclosure of Your Information
▪ Any service provided through Our Platform may be provided by Elite Wealth to render the services through Platform or otherwise. You acknowledge and agree that Elite Wealth may share, disclose,transfer or part with Your Information to Other Entities depending upon the type of Service You are looking for or for one or more of the permissible purposes. Elite Wealth may also share Your Personal or Non Personal information where it is required to share the same with such Other Entities for providing you the service and You provide Elite Wealth, Your unconditional consent to do the same.
▪ Elite Wealth may share statistical data and/or other Non-personal Information or details to facilitate various program or initiatives launched by Elite Wealth, third party service providers, partners or financial institutions, from time to time.
▪ We use other third parties such as a credit/debit card processing company, payment gateway, prepaid cards etc. to enable You to make payments for availing services on Platform. In such case, We may share Your relevant Information as necessary for the third parties to provide such services, including your name, residence and email address. The processing of payments or authorization is solely in accordance with these third parties policies, terms and conditions and we are not in any manner responsible or liable to You or any third party for any delay or failure at their end in processing the payments.
▪ To keep You informed about news, events and ideas regarding Your preferences and help You to improve Your knowledge and skills about the preferred content.
▪ To carry out Our obligations and enforce Our rights arising from any contracts entered into
between You and Us.
▪ To allow You to participate in interactive features offered through Our Platform.
▪ To contact You about Our services that may be of interest to You. If You do not want Us to use Your Information in this way, please adjust Your user preferences in Your account profile.
▪ To produce and share aggregate insights and statistics that do not identify You..
For any other purpose with Your consent. Sharing, Transfer or Disclosure of Your Information:
1) Any service provided through Our Platform may be provided by Elite Wealth to render the services through Platform or otherwise. You acknowledge and agree that Elite Wealth may share, disclose, transfer or part with Your Information to Other Entities depending upon the type of Service You are looking for or for one or more of the permissible purposes. Elite Wealth may also share Your Personal or Non-Personal information where it is required to share the same with such Other Entities for providing you the service and You provide Elite Wealth, Your unconditional consent to do the same.
2) Elite Wealth may share statistical data and/or other Non-personal Information or details to
facilitate various program or initiatives launched by Elite Wealth, third party service providers,
partners or financial institutions, from time to time.
3) We use other third parties such as a credit/debit card processing company, payment gateway, pre
paid cards etc. to enable You to make payments for availing services on Platform. In such case, We
may share Your relevant Information as necessary for the third parties to provide such services,
including your name, residence and email address. The processing of payments or authorization is solely in accordance with these third parties policies, terms and conditions and we are not in any manner responsible or liable to You or any third party for any delay or failure at their end in processing the payments.
4) In addition to this, Elite Wealth reserve the right to share Your Information with any Government
Agency or other authorized law enforcement agencies (LEAs) mandated under law to obtain Your Information for the purpose of verification of identity or for prevention, detection, investigation
including but not limited to cyber incidents, prosecution, and punishment of offences etc.
▪ We may process Your Information outside India ad relay on legally provided mechanisms to
lawfully transfer Your Information across borders.
▪ We may share Your Information in any other circumstances where We have Your consent.
▪ You hereby grant unconditional and unequivocal consent and authorize Elite Wealth while acting on Your behalf for facilitating the transaction on the Platform, to make use of Your vehicle registration number or any other vehicle details as submitted by You on the Platform, to retrieve the information in relation to your motor vehicle or to confirm/ verify respective vehicle details from government or third party websites and applications through use of technological solutions or any other method itself or through third party service providers.
9. Security Measures and Force Majeure

Elite Wealth takes utmost care to secure Your Information from unauthorized access, usage or disclosure or alteration. We take appropriate steps and security measures to safeguard Your Information and make sure that Your Information is secured as mandated by law. For this purpose we adopt reasonable security practices and procedures, in line with the industry standard, to include ,technical, operational, managerial and physical security controls in order to protect your personal information from unauthorized access, or disclosure while it is under our control. While We protect Your Personal information as per industry standards, You acknowledge that the internet or computer networks are not fully secure and that We cannot provide any absolute assurance regarding the
security of Your Personal information. Therefore You acknowledge that You shall not hold responsible Elite Wealth in any manner whatsoever for loss of Your Information, or any other data, which You shares with Us or which We have with Us if such loss or any damage caused to You because of Force Majeure events. You further acknowledge that any information (including your personal information) transmitted to Us or from Your use of Platform will therefore be at Your own risk. It is clarified that Force Majeure events includes any event which is beyond the reasonable control of the Elite Wealth which may include but not limited to sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government,computer hacking, unauthorized access to computer, computer system or computer network, computer crashes, breach of security and encryption.
10. Your Choices to Control Your Personal Information
Change or Correct: We take all endeavors to update Our records with latest information as provided by You, however if you see any discrepancy in Your Personal Information, you may edit some of Your Personal Information or contact Us through Our Data Protection Officer/Grievance Officer to have Your Information updated with Us.
Object to, or Limit or Restrict, Use: You can ask Us to stop using or to limit Our use (in partial or full) Your Personal Information (past, existing or future).
Deletion: You can ask Us to erase or delete (in partial or full) Your Personal Information (past,existing or future).
Right to Access: You can ask Us for a copy of Your Personal Information.
Account Closure: If You choose to close Your Account, we will delete your Personal Information or de- identify it so that it is anonymous and not attributed to your identity. We will retain your Personal Information after You have closed Your account if reasonably necessary to comply with Our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce Our User Agreement, or fulfill Your request to “unsubscribe” from further messages from Us. We will retain de-personalized information after your account has been closed.
Withdraw Consent/Opt-out: At any time, you can withdraw consent that You have provided to Us by going to your account settings, if you have an account with us or otherwise you may request for Withdrawing your consent by writing an email to us at “investorquery@elitewealth.in”. We will only collect and process Personal Information about You where We have lawful bases. Lawful bases include consent (where You have given consent), contract (where processing is necessary for the performance of a contract with You (e.g. to provide services you have requested)) and “legitimate interests”. Where We rely on Your consent to process Personal Information, you have the right to withdraw or decline Your consent at any time and where we rely on legitimate interests, you have the right to object.

You may also contact Us using the contact information below, and We will consider Your request in accordance with applicable laws.

11. Authorization
You also acknowledge that all the information provided by You are out of Your free will and in compliance with applicable laws in Your territory. If We found that any of Your Information is in non
compliance with the terms and conditions and Privacy policy, Elite Wealth reserves the right to remove your non-compliant information from its systems. Further, depending on the seriousness of the non-compliance, we may choose to discontinue some or all of the services being provided to You by Us. In purview of the Telecom Regulatory Authority of India (TRAI) guidelines, You hereby authorize Elite Wealth who is accessing the Your Information by virtue of their association with Elite Wealth to communicate with You through telephone/mobile, Email, SMS or other modes of communication (now available or may be available in future) even if Your number/numbers(s) is/are registered in the National Do Not Call Registry (NDNC) or www.nccptrai.gov.in
12. Change in terms of Privacy Policy
Elite Wealth reserves the right to amend or modify this Privacy Policy at any time, as and when the
need arises. We request you to regularly check this Privacy Policy from time to time to keep you
apprise of changes made. Your continued use of the Platform gives your unconditional acceptance to
such change in terms of Privacy Policy. Particulars of corporate entity, Data Protection Officer/Grievance Officer pursuant to the provisions of Companies Act, 2013 and The IndianInformation T echnology Act, 2000 and rules made and applicable laws thereunder:

Elite Wealth Limited
CIN	U74899HR1990PLC035764
Registered office address:	Casa Picasso, Golf Course Extension, Near Rajesh Pilot Chowk, Radha Swami, Se, ctor-61, Gurgaon, Gurgaon, Haryana, India, 122001
Corporate office address	S-8, DDA Shopping Complex, Mayur Vihar, Phase-1, Delhi – 110091, India

If you have any concern related to this Privacy Policy or collection, storage, retention or disclosure
of Your Information under the terms of this Privacy Policy or Terms of Use or any other terms and conditions of Elite Wealth or its other business entities including any queries or grievances, You can
contact to Elite Wealth through its Data Protection Officer/Grievance Redressal Officer at the below
given details:

Name :	Mr. Diwan Singh
E-mail :	investorquery@elitewealth.in
Telephone Number :	+91-9871195533
Working Days: :	Monday to Saturday(alternate) Working Hours: 09:00 am to 6:00 pm

We will strive to address your feedback and concerns in a timely and effective manner.

Please note that the details of the Data Protection Officer/Grievance Officer may be changed by Us from time to time by updating this Privacy Policy.

13. Invoices

If no action is taken with respect to invoice generation process within 72 hours of the receipt of intimation via SMS, the same shall be treated as deemed acceptance for the generation of invoice on your behalf, as per records available in our system.
Please note that the SMS would be generated twice for the same period. The 72 hours will commence
post-delivery of the second SMS.

14. Disclaimer

In spite of its best efforts to protect the interest of its clients it is made clear that in the unlikely event of any data theft or, misuse, Elite Wealth Limited will not be liable in any way. The policies uploaded in the website of Elite Wealth are illustrative in nature, and the rights and liabilities of the parties are to be governed strictly by the actual contract entered into and signed by the parties thereto.

The party intending to seek insurance cover from Elite Wealth Limited may at its option, pay extra premium and get add-on coverage in respect of the particular insurance policy.

Feedback

Elite Wealth Limited (Elite Wealth) welcomes feedback regarding this Policy at info@elitewealth.in .
If at any time believe that Elite Wealth has not adhered to this Privacy Policy, please send feedback
and we shall endeavor to resolve the same.
Some of the services and facilities mentioned above may not yet be available or may have been
withdrawn at the discretion of Elite Wealth Limited.