Privacy Policy

1. INTERPRETATION

For the purpose of this policy:

1.1 Whenever the context so requires, “You”, “you”, “your”, “user”, and “User” shall mean any natural or legal person who browses through the Platform and/or avail services through the Website, and the terms “we”, “We”, “us”, and “our” shall mean the Entity.

2. INTRODUCTION

The Wealth Makers (“TWM”) is committed to ensuring that your privacy is protected. This policy is provided to explain our policies and practices regarding the collection, use, and disclosure of informationand/or otherwise treats personal information through our website, www.twmks.com, including all subpages and successor pages and other interactions with our clients and prospective clients. This Privacy Policy may be updated periodically to reflect changes to our information practices. TWM strongly encourages you to refer to this Privacy Policy often for the latest information about our personal information practices.

The Wealth Makers asks our clients for no more personal information than necessary. The need to collect personal information from our clients and prospective clients is to provide services to them. Understanding a client’s needs and wants, financial position and family background enable us to ensure that all recommendations related to finance or investment products are suitable. This is both a regulatory requirement and good business. We are committed to protecting our clients’ privacy and the confidentiality of their personal information in our possession. This memorandum explains the measures we take to fulfill these commitments.
For the purpose of performing its obligations for the provided service, TWM will be required to obtain data from the User, which shall be used by TWM for processing. By undergoing the sign-up process or submitting us the personal information and/or documents, you consent to us collecting your personal data including your images and we will store, use or disclose such data in accordance with this Privacy Policy. Clients can browse certain sections of the TWM website without being a registered member, therefore in order to avail of certain Services of our Platform (such as enquiring for an Investment plan or loan product) Clients are required to submit their information with Us. This Privacy Policy applies to the information (“Personal Information”) that:

Clients may provide Us with information, voluntarily while using Our Platform for using Our Services, such as name, mobile number, email address or any other basic personal information that may be required for processing an application.

TWM may also ask clients for certain financial information, including their billing address, bank account details that may be required to process an application. For any further additional information, TWM may ask clients to provide it on a case-to-case basis. All information disclosed by clients shall be deemed to be disclosed willingly and without any coercion.
All transactional information including financial information gathered by TWM shall be stored on servers, log files, and any other storage system owned by us or by third parties in India. Clients can browse the Platform without telling Us who they are or revealing any Personal Information about themselves. In such a case, TWM will only collect and store the Non–Personal Information. Once clients share their Personal Information with us then they will be not anonymous to Us. TWM shall be entitled to retain clients’ Personal Information and other information for such duration as may be required for the purposes specified hereunder and will be used by Us only under this Privacy Policy.

This Privacy Policy delineates the way of collection, use, retention, and management of your information by us. By using TWM or voluntarily sharing information on TWM, you consent to be bound by the terms of this Privacy Policy, and you further consent to the collection, use, retention, and management of your information under the terms and conditions of this Privacy Policy.

We, therefore, advise you to read this policy before using our Platform. If these terms, in parts or whole, are not acceptable to you, then you are advised not to use TWM or our Services that require the collection, use, or retention of your information.

TWM will not sell or rent the Customer’s confidential information to any other Party, for any reason, at any time. TWM uses and discloses the Customer’s information as follows:

• To facilitate the processing of the transaction
• To analyse TWM usage and improve the Services;
• To deliver to the Customer any administrative notices, money alerts and communications relevant to the Customer’s use of the Services;
• To fulfill the Customer’s requests for certain products and services;
• To third-party contractors that provide services to TWM and are bound by these same privacy restrictions;
• To provide payment history information to the bank/financial institution providing financing or to a Credit Bureau established under the rules and regulations of the country.
• To enforce TWM’s Terms of Use; and
• as otherwise set forth in this Privacy and Security Policy.

TWM will use Personal Information and other Non-Personal Information, for the following reasons:

(i) improvising the Services on the Platform that our clients may request; (ii) to rectify the disputes and troubleshoot problems; (iii)Protecting the security and integrity of the Platform, its Services, and for its clients; (iv) Collection of money from clients concerning the Services, (v) Informing clients about online and offline offers, products, services, and updates; (vi) customize Your experience on the Platform or share marketing material with You; (vii) To protect, detect and prevent TWM from any errors, fraud, and other criminal or prohibited activity on the Platform; (viii) Enforcing and informing clients about our terms and conditions; (ix) Contacting our clients (x) Allowing Our business partners and/or associates to share customized messages to our clients; The client will also specifically agree and give consent to TWM for collecting, storing, processing, transferring, and sharing information (including Personal Information) related to them with third parties such as Banks, financial institutions, credit information companies, entities registered under applicable laws solely to review their profile and processing clients transaction requests for the Services or such other products/services offered by us or our group, affiliate or associates. In addition to the above, TWM will identify and use clients’ IP addresses to help diagnose problems with Our server, therefore, resolve such problems and administer the Platform.

TWM may also disclose clients Personal Information to third-party vendors, consultants, and other service providers who work for the Entity and are bounded by the obligations to keep personal information confidential, therefore to use it only for the purposes for which TWM discloses it to them. This disclosure may be required for us to provide you with the access to Our Services and process payments including validation of clients’ bank accounts. This will be done to facilitate and assist Our marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to Our Services. Most importantly we ensure not to disclose our client’s Personal Information to third parties for their marketing and advertising purposes without our client’s explicit consent.

TWM may disclose Your information, to the extent necessary:
(i) to comply with laws and to respond to lawful requests and legal processes, (ii) to protect the rights and property of the Entity, Our users, and others, including to enforce the Terms, and (iii) in an emergency to protect the personal safety and assets of the Entity, the users, or any person. In such an event the Entity is in no manner responsible for informing You or seeking Your approval or consent.

TWM carries reasonable security measures to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration of the information in compliance with applicable laws. TWM cannot ensure or warrant the security of any information You transmit to us or guarantee that Your Personal Information and/or other Non-Personal Information provided for availing the Services or Platform may not be accessed, disclosed, altered, or destroyed by a breach of any of Our security measures and safeguards. It is further clarified that the client has access to and/or uses the Platform (directly or indirectly) the obligation to ensure that they shall at all times, take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information.

The Entity has undertaken reasonable measures to protect Your rights of privacy concerning Your usage of the Platform controlled by Us and Our Services. TWM shall not be liable for any unauthorized or unlawful disclosures of Your personal information made by any third parties who are not subject to Our control.

ONLINE SESSION INFORMATION AND USE IS ONLY USED TO IMPROVE THE CUSTOMER’S EXPERIENCE

When the Customer visits TWM, TWM may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on TWM. This information may be used, for example, to alert the Customer to software compatibility issues, or it may be analysed to improve TWM design and functionality.

TWM may use third party service providers to help us analyse certain online activities. For example, these service providers may help us measure the performance of TWM’s online campaigns or analyse visitor activity on TWM. TWM may permit these service providers to use cookies and other technologies to perform these Services for TWM. TWM does not share any personal information about TWM’s customers with these third-party service providers, and these service providers do not collect such information on TWM’s behalf. TWM’s third party service providers are required to comply fully with this Privacy Policy

DISCLOSURE OF CUSTOMER’S INFORMATION TO PROTECT TWM’s RIGHTS OR IF REQUIRED BY LAW

Notwithstanding the foregoing, TWM reserves the right (and the Customer authorizes TWM) to share or disclose the Customer’s personal information when TWM determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:

• To enforce TWM’s rights against the Customer or in connection with a breach by the Customer of this Privacy and Security Policy or TWM’s Terms of Use;

• To prevent prohibited or illegal activities; or

• When required by any applicable law, rule regulation, subpoena or other legal process.

THE CUSTOMER’S DATA MAY BE TRANSFERRED UPON ACQUISITION OF TWM BUT ONLY IN ACCORDANCE WITH THIS POLICY

Credential information may, with prior intimation to the Customer and upon its authorization, such authorization not to be unreasonably withheld, be transferred to a third party as a result of a sale, acquisition, merger, re-organization or other transfer (a “Transfer”) involving TWM, to continue processing of transactions. Should such a Transfer occur, TWM will use its best efforts to require that the new combined entity follow this Privacy and Security Policy with respect to the Customer’s personal information, as and to the extent required by applicable law and to require that the Customer receive prior notice if the Customer Data could be used contrary to this Policy. Pending authorization from the bank/financial institution for such a transfer of Credential Information, the Customer accepts that there could be disruption to Services delivered by TWM.

Email Communication from TWM

TWM may allow organizations to subscribe to email newsletters and from time to time may transmit emails promoting TWM.

TWM customers have the ability to opt-out of receiving TWM’s promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts.

Changes to Privacy Policy:

TWM updates this Privacy & Security Policy periodically. TWM reserves the unconditional right to change, modify, add, or remove portions of this

Privacy Policy at any time, without specifically notifying clients of such changes. Any changes or updates will be effective immediately. Clients should review this Privacy Policy regularly for changes. By accessing TWM’s website and using its Services, you hereby declare that you have read the privacy policy and agreed to its contents.

We reserve the right to withdraw or amend our Services, and any Services or material we provide via Services, in our sole discretion without notice. We will not be liable if for any reason all or any part of Services is unavailable at any time or for any period. From time to time, we may restrict access to some parts of Services, or the entire Services, to users, including registered users.

3. DEFINITION

3.1. “Information” means your data that is collected during your usage of TWM Services and includes Personal, Non-personal, and financial information.

3.2. “Personal Information” means personally identifiable information that can be used to contact or identify you or the User. Personal information includes, without limitation, the name, email address, residential and permanent address, date of birth, phone number, aadhar card, pan card, photos/images and other financial information, including, without limitation, income, expenses, payment details, bank accounts information and other information as required from time to time.

3.3. “Non-personal Information” means information such as cookies, log data, third-party analytics for data collection, and analysis that your browser sends whenever you use TWM, and includes, without limitation, information such as your computer’s Internet Protocol address, browser type, browser version, pages of Website that you visit, time and date of your visit, time spent on those pages, unique device identifiers, the mobile device you use (including the hardware models), your mobile device unique ID, IP address of your mobile device, your mobile operating system, type of mobile Internet browser you use, unique device identifiers, location, device data, and other diagnostic data.

3.4. “User” shall mean the User who uses the platform and provides information on the Platform.

4. COLLECTION OF INFORMATION

4.1. Non-personal Information:
We collect your Non-personal Information, such as the device ID, device model, IP address, browser type, operating system, and the time and frequency of use of our Website, when you browse through our Website or use TWM to avail of the Services.

4.2. Personal Information:

We collect your Personal Information only when you voluntarily provide it to us while:

(a) Browsing TWM
(b) Availing Services available on TWM
(c) Inquiring about our Services
(d) Providing feedback
(e) Using live chat support
(f) Availing service support
(g) Providing Information on our Platform

• Camera Access: We may require access to Your mobile device camera in case some part of the journey is to be completed on your mobile device for clicking Your selfie and uploading photos/images for Your KYC compliance and/or for uploading any other necessary documents on the application.

• Storage: We may require this permission so that Your documents can be securely downloaded and saved on Your phone and so You can upload any required documents. This helps in providing a smooth and seamless experience while using the application.

• Third-Party Information: Only after the consent, We or the Financing Partner may also work closely with third parties (including, for example, information bureaus, account aggregators, business partners, technical sub-contractors, analytics providers, search information providers, etc.) and may lawfully receive information about You from such sources. Such data may be combined with data collected on the application and other information provided in this policy. Such third parties will provide the same or equal protection to the user data as provided in this policy.
Cookies: These are alphanumeric identifiers in the form of text files that are inserted and stored by the Customer’s web browser on the Customer’s computer’s hard drive. TWM may set and access cookies on the Customer’s computer to track and store preferential information about the Customer. TWM may gather information about the Customer through cookie technology. For example, TWM may assign a cookie to the Customer, to limit the number of times the Customer see particular information or to help better determine which information or preference settings to serve to the Customer. Please note that most Internet browsers will allow the Customer to stop cookies from being stored on the Customer’s computer and to delete cookies stored on the Customer’s computer. If the Customer or other users choose to eliminate cookies, the full functionality of the Service may be impaired for the Customer.
TWM’s cookies are encrypted so that only TWM can interpret the information stored in them.

Third party cookies: The Website allows cookies of social plugins of several third parties. This enables a user to share content of the Website on certain social networks. These plugins also enhance the user friendliness of the Website. For example, with the Facebook plugin on the Website, users can simply register themselves on the Website with their Facebook account details. The (use of the) data collected by these third parties via the social plugins are exclusively determined by such third party as TWM cannot read these cookies (nor can these parties read the cookies of TWM). For information regarding the third-party cookies, please read the respective third party’s policies.

Web beacons are images embedded in a web page or email for the purpose of measuring and analysing site usage and activity. TWM, or third party service providers acting on TWM’s behalf, may use web beacons to help us analyse Website usage and improve the Services.

4.3. Disclaimer:

We do not collect any Personal Information of any individual except when such individual voluntarily shares Personal Information on our Platform. Upon such voluntary disclosure of Personal Information and data, we may further verify and collate the information and data from information available in the public domain (as permitted by law) to prevent identity theft, fraud, etc.

5. RETENTION OF DATA

You can choose to edit, change or delete your Personal Information, in parts or whole, that you have provided on TWM. We will retain your Personal Information as long as you continue to remain a user of TWM by using Services available on TWM or until it is required for us to retain your Personal Information to resolve disputes, if any, or to enforce our legal agreements and policies.

When the user requests TWM to delete the user’s data for the Service, the user’s data will be permanently expunged from TWM’s primary production servers and further access to the user’s account will not be possible. However, anonymized data, consisting of aggregate data derived from the user’s account information, may remain on TWM’s production servers indefinitely. The user’s data may also remain on a backup server or media. TWM keeps these backups to ensure TWM’s continued ability to provide the Services to the user in the event of malfunction or damage to TWM’s primary production servers. TWM will also keep the audit data on its servers from a compliance perspective. TWM may allow organizations to subscribe to email newsletters and from time to time may transmit emails promoting TWM. TWM customers have the ability to opt-out of receiving TWM’s promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts.

5.1 Data deletion requests

You can request your data to be deleted by emailing us at supportdesk@twmks.com with the subject line “Delete My Data”

6. DISCLOSURE OF DATA

6.1. We will not voluntarily disclose your stored information without your prior written consent.

6.2. Notwithstanding the foregoing, TWM reserves the right (and the User authorizes TWM) to share or disclose the User’s personal information when TWM determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:

6.2.1 To enforce TWM’s rights against the User or in connection with a breach by the User of this Privacy and Security Policy or TWM’s Terms of Use;

6.2.2 To prevent prohibited or illegal activities; or

6.2.3 When required by any applicable law, rule regulation, subpoena or other legal process.

6.3. Permitted Disclosure: Notwithstanding anything provided in the foregoing clause, we will disclose your information in parts or whole under the following conditions:

6.3.1 Third-Party Service Provider (Financial Institutions): For providing Services available on TWM which is rendered to you through the help of third-party service providers (Financial Institutions) such as Banks, Non-Banking Financial Company (NBFC), Insurers, Brokers, Mutual Funds, AMCs, etc. we may be required to share your information, in part or whole, to third-party service providers; thereby we will share your information with such third-party service provider as required for rendering such Services to you. Such disclosure, however, shall be made under strict confidentiality obligations, which inter alia restricts disclosure of your information to any person or entity by a such third party, its employees, associates, and affiliates.

6.3.2 Disclosure for Law Enforcement: Entity will disclose your information to law enforcement agencies, Governmental authorities, or any other third party if so is required by a court order or under any law enforced from time to time, in good faith, or to enforce the terms of use or privacy policy of TWM.

6.3.3 Legal Requirements: We will disclose your information in good faith and belief if such action is necessary to comply with a legal obligation or to protect and defend the rights and property and restrict the legal liability of the Entity, or to prevent or investigate possible wrongdoing in connection with the Platform or to protect the personal safety of the users of TWM.

6.3.4 We shall not be held liable for disclosure of the User Information or Statistical Information in accordance with this Privacy Commitment or in terms of any other agreements with you.

6.3.5 We may disclose User Information to any of our associates and affiliates without any limitation, and you hereby give your consent for the same.

6.3.6 We may disclose the User Information, to third parties, without limitation, for the following reasons, and you hereby give your irrevocable consent for the same:

6.3.7 To enforce the Terms and Conditions of the products or Services. Or

6.3.8 To protect or defend our rights, interests and property or that of our associates and affiliates, or that of our or our Affiliate’s employees, consultants etc. or

6.3.9 For fraud prevention purposes. or

6.3.10 As permitted or required by law.

6.3.11 We may disclose the User Information to third parties for the following, among other purposes, and will make reasonable efforts to bind them to the obligation to keep the same secure and confidential and an obligation to use the information for the purpose for which the same is disclosed, and you hereby give your irrevocable consent for the same:
(a) For participation in any telecommunication or electronic clearing network.
(b) For advertising. or
(c) Facilitating joint product promotion campaigns. or
(d) For availing of the support services from third parties, e.g. collecting subscription fees and notifying or contacting you regarding any problem with, or the expiration of, any Services availed by you.

6.3.12 For sharing with third-parties information obtained once (such information will only be taken one time, the information obtained once will only be shared) with your consent from your mobile device like device location, device information (including storage, model, installed apps, Wi-Fi, mobile network), transactional and promotional SMS, communication information including contacts and call logs, for statistical modelling, scoring and any other purpose that will help us in providing you with optimal and high-quality services.

7. USE OF INFORMATION

7.1. By the Entity:

7.1.1 We will use your information to provide Services available on TWM to you; to notify you about changes in our Services or terms and conditions for such Services, or deliver any administrative notices, alerts, advice, notifications, and communication relevant to Your use of any of the facilities on the application through social media, Instant messaging, SMS and other mediums; to allow you to participate in interactive features of TWM when you choose to do so; to provide service support, gather valuable information or analysis to improve our Platform and Services provided thereof.

7.1.2 We will use your information and analyse your usage of the application to improve and develop our Platform and Services provided thereof by gathering and analysing surveys taken, feedback, reviews, and ratings provided or posted by you.

7.1.3 To fulfil KYC (Know Your Customer) compliances under anti-money laundering laws applicable from time to time.

7.1.4 We shall collect any Files & Media (Images) for facilitating KYC journey, lending services and such purposes as may be required by the Lending Partners or as per applicable law.

7.1.5 To provide service support and promptly and satisfactorily respond to and resolve your queries, complaints, and grievances, if any.

7.1.6 Undertake market research, project planning, and problem troubleshooting and to protect against error, fraud or other criminal activity

7.1.7 Disclose to employees, agents and representatives on a need-to-know basis as part of the Services

7.1.8 Disclose to relevant and authorised financial service providers and Financing partners who have partnered with TWM to provide loan facilities to the users.

7.1.9 Assist in resolving disputes in relation to loan facilities made available by Financing Partners

Disclose to the information bureau and such other authorities as may be required by applicable laws and such other purposes as provided in this policy.

TWM may also be required to share Personal Information with its third-party contractors, such as financial service providers, banks, or NBFCs/Financing Partners. In such cases, TWM shares the information securely and ensures that all personal information recipients comply with confidentiality, fidelity and secrecy obligations and sign covenants in this regard. Such third parties will provide the same or equal protection to the user data as provided in this policy. TWM may make information available to third parties that are financial and non- financial companies, such as service providers, government agencies, courts, legal investigators, and other non-affiliated third parties, as requested by You or Your authorised representative, or otherwise when required or permitted by law.

The account information and profile are password protected. TWM will never ask for Your password through unsolicited phone calls or emails. However, if any person claiming to be an authorised representative of TWM contacts You, we request You not to provide any information to such person and instead immediately contact TWM as per the contact details provided in this policy. TWM shall not be liable for any loss of Personal Information provided to such persons.

7.2 By Third-Party Service Provider: We engage third-party service providers (Financial Institutions) to render certain Services; thereby, your information will be used by such third- party service providers solely and strictly to provide the Services to you. Sharing of Information is limited to the extent necessary for rendering such Services and is shared under the strict obligation of confidentiality subject to the permitted disclosure provided under this Privacy Policy. Your information will be used by third-party service providers for the following purposes as stipulated under this policy.

7.2.1 Web Analytics: We use third-party service providers to monitor and use our Platform to track and report traffic on the Platform; thereby, the web analytics service providers may use the collected data to contextualise and personalise advertisements of their own advertising network. Kindly refer to their respective privacy practices to understand your data usage by these service providers. You can access the Privacy Policy and terms of use of these service providers on their respective websites.

7.2.2 Other third-party service providers and facilitators: Your information will be used by other third parties, such as banks, NBFCs, etc., when you use TWM for availing Services on TWM.

8. THIRD-PARTY LINKS AND CONTENTS THEREOF

Our Platform may link to third-party websites and services that are outside our control. Such third- party websites may collect and store information and data about the user. The Entity takes no responsibility for the privacy practices followed by these websites or the content available thereon. The Entity takes no liability for any loss or damage arising directly or indirectly from using such websites by browsing or transacting through them.

9. SECURITY OF DATA

9.1 We have implemented and employed existing and necessary internet security methods and technologies to secure the information and data, to prevent loss and misuse of the information, and to data disclosed through unauthorised access from third-party, alteration, disclosure, or destruction of your information, username, password, transaction information and other stored Information on TWM.

9.2 We assure the compliance and adoption of all such measures as required under the applicable laws from time to time.

9.3 The protection and confidentiality of your credentials is solely your responsibility, and we recommend you not to disclose it to anyone, including any third party, including anyone claiming to be the representative of the Entity or its affiliates. We never call or ask for such information from users. We shall not bear any responsibility or liability for such unauthorised disclosure or usage of your information or action taken from your account and its consequences thereof.

9.4 Notwithstanding anything provided under this policy, the Entity shall be under no obligation for the permitted disclosure of information as per the terms of this policy.

9.5 Although we use our best endeavours to protect and secure the information and data shared or transmitted over the internet cannot be completely guaranteed; hence we cannot provide an absolute hundred percent guaranteed security of the information provided by the user. Therefore, we disclaim all warranties and liabilities in respect of:

9.5.1 Any loss or injury caused to you as a result of voluntary disclosure of your Personal Information to any unauthorised party.

10. Online Session Information and Use Is Only Used To Improve The User’s Experience

When the User visits TWM’s Website, TWM may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on TWM. This information may be used, for example, to alert the User to software compatibility issues, or it may be analysed to improve TWM design and functionality. “Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by the User’s web browser on the User’s computer’s hard drive. TWM may set and access cookies on the User’s computer to track and store preferential information about the User. TWM may gather information about the User through cookie technology. For example, TWM may assign a cookie to the User, to limit the number of times the User see particular information or to help better determine which information or preference settings to serve to the User. Please note that most Internet browsers will allow the User to stop cookies from being stored on the User’s computer and to delete cookies stored on the User’s computer. If the User or other users choose to eliminate cookies, the full functionality of the Service may be impaired for the User. TWM’s cookies are encrypted so that only TWM can interpret the information stored in them. Third party cookies. The website allows cookies of social plugins of several third parties. This enables a user to share content of the Website on certain social networks. These plugins also enhance the user friendliness of the Website. For example, with the Facebook plugin on the Website, users can simply register themselves on the Website with their Facebook account details. The (use of the) data collected by these third parties via the social plugins are exclusively determined by such third party as TWM cannot read these cookies (nor can these parties read the cookies of TWM). For information regarding the third-party cookies, please read the respective third party’s policies.

Web beacons are images embedded in a web page or email for the purpose of measuring and analysing site usage and activity. TWM, or third-party service providers acting on TWM’s behalf, may use web beacons to help us analyse Website usage and improve the Services. TWM may use third party service providers to help us analyse certain online activities. For example, these service providers may help us measure the performance of TWM’s online campaigns or analyse visitor activity on TWM. TWM may permit these service providers to use cookies and other technologies to perform these Services for TWM. TWM does not share any personal information about TWM’s users with these third-party service providers, and these service providers do not collect such information on TWM’s behalf. TWM’s third party service providers are required to comply fully with this Privacy.

11. AMENDMENTS

We update our Privacy Policy to comply with applicable laws as amended from time to time. You are requested to periodically review the policy to apprise yourself of the requisite changes. All such changes shall be effective immediately upon posting the updated policy on the Platform.

Your continued use of the Platform following the posting of revised Terms means that you accept and agree to the changes. You are expected to check this page frequently, so you are aware of any changes, as they are binding on you.

By continuing to access or use our Services after any revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, you are no longer authorized to use our Services.

12. GRIEVANCE REDRESSAL

TWM uses stringent security measures to prevent loss, misuse or alteration of information under our control. If any user has sufficient reason to believe that their data has been compromised or there has been a breach of security, you may write to us immediately on the contact details given in this policy so that we may take suitable measures to either rectify the breach and inform the concerned authorities if need be. If you have any questions related to this Privacy Policy or any other grievance related to your information’s privacy, you can write to us at supportdesk@twmks.com or call us at +919833173797.