Privacy Policy

Superlative is committed to safeguarding the confidentiality of the User’s Personal Information (as defined below) collected by it by utilizing best in class software and hardware architecture, techniques, methods and procedures which allow the User to enjoy the Services available on the Site with the knowledge that the User’s privacy is safeguarded. Superlative has developed this “Privacy Policy” which covers how Superlative collects, uses, discloses, transfers, and stores User information. Users are advised to familiarize themselves with Superlative’s privacy practices. 

By mere use of the Site, the User expressly consents to Superlative’s use and disclosure of the User’s Personal Information in accordance with this Privacy Policy. This Privacy Policy is subject to change at any time without notice. To make sure the Users are aware of changes, if any, Users are advised to review this policy periodically. This Privacy Policy shall be deemed to be incorporated into the End User License Agreement available here (“Agreement”) and shall be read in addition to the Agreement. In the event of any inconsistency or ambiguity arising between the Agreement and the terms of this Privacy Policy, the provisions in this Privacy Policy to the extent of such inconsistency or ambiguity, shall prevail. 

For the purpose of this Privacy Policy, all capitalised terms shall have the meaning so assigned to them in the Agreement.

1. Collection and use of Personal Information

1. As a part of the User Account opening process, and to allow us to make the Services available to you, we will ask you to provide us, certain personal information, including but not limited to your name, date of birth, permanent account number, postal address, contact number, e-mail address (collectively referred to as "Personal Information") and a confirmation that you are at least 18 years old. 

2. It is clarified that you can only use the Services if you are physically present in such specific states in India that Superlative may require and where the use of the Services is not prohibited by law. To comply with the regulatory requirements applicable to Superlative, and in order for you to access and use the Service, you hereby consent and permit us (or third parties acting on our behalf) to: (i) use location-based services (LBS) to detect your geographic location from your PC/Device (which may include but not be limited to your IP address, GPS coordinates, Cell Tower Data (such as Cell ID and Location Area Code), Wi-Fi connection (such as MAC Address) and cookies data); and (ii) undertake the collection, storage, processing, retrieval and transmission of your Personal Information (which will include but not be limited to your location data) and/or such other data or information that may be derived from your Device, in accordance with this Privacy Policy. 

3. We and our service providers may also use any or all of your Personal Information to verify your credentials from third parties including financial institutions, identification verification agencies, and credit reference agencies for enabling us to provide the Services to you. 

4. In addition, when you use the Service we also store and share certain Personal Information, including information about your activity on the Site and information held on or derived from Devices that you use, to allow us to enhance the Services that we provide to you, as well as to ensure that you are not using any prohibited third party software or tools. 

5. We will take all reasonable efforts to ensure that the User information shared by us with third parties is protected in a manner that is consistent with this Privacy Policy. We, our affiliates and third parties providing services to us or on our behalf (whether in India or outside India), will use your Personal Information for various purposes such as:

1. to process or confirm financial transactions on the Site,

2. to provide the Services to you;

3. identification, verification and vetting purposes;

4. statistical analysis and research;

5. research and development;

6. marketing, market research, and customer profiling;

7. data analysis;

8. to comply with licensing and regulatory requirements;

9. to analyze your credit risk;

10. to combat against security risks;

11. for disaster recovery;

12. to confirm your geographic location; and

13. to send to you, promotional communications (after seeking specific consent from you where applicable).

6. If the User’s Personal Information is processed by Superlative, its affiliates, agents and third party service providers, in jurisdictions outside India, Superlative will comply with the terms of the applicable legislation in force concerning any such processing and/or transfers of the User’s Personal Information. 

7. By accepting the terms of this Privacy Policy, you hereby consent to your Personal Information being shared, where necessary, outside of India. We will only use your name in publicity materials with your consent. 

8. You are required to create a User Account by using your own name. It is very important that you complete the User Account registration process with valid information since it will be used in the course of validating financial transactions and the other aforementioned purposes. You are required to advise us of any relevant changes to your Personal Information provided by you to us. Users can change the information provided upon registration by accessing the dedicated User Account details section when they log in. Kindly note that requests for changes to your User Account details, such as changes to your name and permanent account number, would need to be accompanied by an adequate government-issued documentary proof to be effective.

2. Deposit and withdrawal processing

In the course of making a deposit, you consent to providing us, or our duly appointed third party payment processors or our service providers, with the deposit method information and other relevant financial information (example: credit card number, debit card number and other payment instrument information). This information in conjunction with your other Personal Information which might be used, either by us or by third party payment processors appointed by us or service providers to process financial transactions executed by you. 

3. Confidentiality

We undertake substantial efforts to protect the confidentiality of your Personal Information and will not knowingly allow access to your Personal Information to anyone other than you or as described in this Privacy Policy. Our systems will protect your data in line with international standard ISO/IEC 27001 on "Information Technology - Security Techniques - Information Security Management System - Requirements" standards or equivalent. You should also do your part in protecting your information. Your Login Credentials are confidential and you are obliged to keep your Login Credentials secret and confidential at all times and to use your best efforts to protect their secrecy and confidentiality.

4. Limits of Confidentiality

1. It may be necessary by law, legal process, litigation, and/or requests from public and government authorities for us to disclose your Personal Information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

2. Further, we can, and you hereby give your authorization to, disclose your Personal Information, including, name, date of birth, age, street address, city, state, postcode, country, phone number, e-mail, geo-location data, details of your payment transactions on the site, including the financial instruments used to deposit and withdraw funds, to third party advisors or official government bodies as they believe, in their sole discretion, necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose them to legal liability.

3. We may disclose your Personal Information to Cerebro Palaestra Limited (Malta) its group companies, and to its employees, agents and to third-party service providers, who may use your Personal Information to provide services to us in respect of the Services provided by us to you. All recipients mentioned in this Clause, of your Personal Information shall be bound by applicable data protection laws to keep such Personal Information confidential and will treat them per this Privacy Policy and your marketing preferences.

5. Direct Marketing

1. If requested by you at initial registration or as per the marketing preferences provided by you on the Site, we may send you, information by email, text message or post (as selected by you), or by any other electronic modes, or by any contact details you provide directly to us, about existing and new services, products, competitions and offers from us in accordance with this Privacy Policy. 

2. We may also share your email address and phone number with our marketing partners to provide you with marketing offers concerning our services. If you do not wish to receive any information about existing and new services, products, competitions, prizes and special offers from us, you can intimate us about such preference by updating your marketing preferences in the ‘My Account’ section of the Site or by clicking on the unsubscribe link in any marketing email that you may receive from us. 

3. Upon receipt of such a request from you to discontinue receiving marketing communications, we will delete your details from our marketing distribution lists and from any future lists we may share with our marketing partners. However, you may need to unsubscribe separately from marketing offers sent by our partners.

6. Access to personal information

You can write to us at any time to review, change or obtain a copy of your information provided by you to us and upon receipt of such request from you, we may require evidence of your identity to process such request. We may, in certain circumstances levy a small charge to cover the cost of administration regarding any request made by you in this regard if the information is sought by you in writing. If we delete, or if you request us to delete your User Account for any reason, your details will be retained for such period as may be required under applicable anti-money laundering regulations or other regulatory requirements.

7. Cookies

Cookies are text-only strings of information that are downloaded to your Device when you visit a website. They are then sent back to the originating website on each subsequent visit, or to another website that recognizes those cookies. Cookies are very useful and are used for many different purposes. These include allowing you to navigate between pages efficiently, remembering your preferences, and generally improving user experience. Sometimes cookies are used to help ensure that advertisements you see online are relevant to you and your interests. We use cookies to track referrals to our Site, to remember your preferences, and to generate anonymized statistical data, which we use to improve the user experience on our Sites. We also use cookies to measure the effectiveness of our advertising campaigns, to limit the number of times you see an advertisement, to remember that you have visited a website, and to provide advertisements that are more relevant to your interests. We may use the data generated from cookies to compile statistical data on your use of our Site. You are not obliged to accept the cookie from the Site and you can accept or decline cookies by modifying the settings in your internet browser, although in that case you may not be able to use certain features on the Site and you may be required to re-enter your details more frequently during a session.

8. Limitation of Liability

1. Superlative is not responsible for any breach of security or for any actions of any third parties that receive the User’s Personal Information.

2. Notwithstanding anything contained in this Privacy Policy or elsewhere, Superlative shall not be held responsible for any loss, damage or misuse of the User Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event (as defined below).

3. A “Force Majeure Event” shall mean any event that is beyond the reasonable control of Superlative and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, civil disturbances, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, and any other similar events not within the control of Superlative and which Superlative is not able to overcome.

9. Grievance Officer

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

E-mail: [email protected]

This Privacy Policy is in force from [February [05th], 2021].