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Privacy Policy

Last updated: [Effective Date]

Note:This policy is a working template aligned to India's Digital Personal Data Protection Act, 2023 (DPDP Act) and the DPDP Rules. It must be reviewed and finalized by a qualified legal professional, with all [bracketed] fields completed, before publishing.

Centure (“Centure,” “we,” “us,” or “our”), operated by [Centure Legal Entity Name], registered at [Registered Address], is committed to protecting your personal data. This Privacy Policy explains what we collect, why, how we use and protect it, and the rights you have over it. By using the Centure app or website (together, the “Platform”), you agree to this policy.

For the purposes of the DPDP Act, Centure is the Data Fiduciary and you are the Data Principal.

1. Information we collect

Identity & contact data — your name, mobile number, email address, and date of birth.

KYC & verification data — information required to verify your identity and enable investing, such as PAN and KYC status. Where possible, this is handled by our regulated broker/KYC partners, and we store references or tokens rather than raw documents.

Financial & transaction data — the payment amounts we use to compute your round-ups, your chosen rounding rules and thresholds, your linked bank and demat/broker account details, and your investment activity, holdings, and portfolio.

Device & usage data — device information, app version, IP address, and how you interact with the Platform, collected to keep the service secure and working.

Payment data — subscription billing information, processed by our payment partner. We do not store your full card or bank credentials.

Communications — messages you send to our support team.

2. How we collect it

We collect data directly from you (when you sign up, set your rules, or contact us), automatically as you use the Platform, and from partners (such as our broker for KYC/holdings status). On Android, where you grant permission, our app reads payment notifications on your device to detect transactions — parsing happens on your device, and only the transaction amount and merchant are sent to us. We never read or transmit the full contents of your messages or notifications.

3. Why we use your data (purposes)

We process your data to: create and manage your account; compute round-ups and run your wallet; help you invest through our broker partner into your own demat account; provide the Platform's features and personalization; process subscriptions; provide customer support; keep the Platform secure and prevent fraud; and comply with legal and regulatory obligations.

Legal basis: we process your data based on your consent and, where applicable, for legitimate uses permitted under the DPDP Act. You may withdraw consent at any time (see Section 7).

4. How we share it

We do not sell your personal data. We share it only as needed to run the service, with:

  • Our broker partner (a SEBI-registered broker, e.g., Angel One) to open/link your demat account and execute investments in your own name;
  • Payment processors (e.g., Razorpay) to handle subscription billing;
  • KYC, cloud hosting, analytics, and communication providers who process data on our behalf under contract;
  • Regulators, authorities, or courts where required by law.

Important: Centure never holds or pools your investment money. Funds move between your bank and your own broker/demat account; we only facilitate and instruct.

5. Data security

We implement reasonable technical and organizational safeguards — including encryption in transit and at rest, access controls, and monitoring — to protect your data against unauthorized access, loss, or misuse. No system is perfectly secure, but we work continuously to protect your information and will notify you and the Data Protection Board of a personal data breach as required by law.

6. Data retention

We retain your personal data only as long as necessary to provide the service, comply with legal, regulatory, and tax obligations, and resolve disputes. When it is no longer required, we delete or anonymize it.

7. Your rights (as a Data Principal)

Under the DPDP Act, you have the right to:

  • Accessa summary of the personal data we hold about you and how it's processed;
  • Correct, complete, or update inaccurate data;
  • Erase your personal data where it is no longer required;
  • Withdraw consent at any time (this may limit your ability to use certain features);
  • Nominate another individual to exercise your rights in the event of death or incapacity;
  • Grievance redressal — raise a complaint with us and, if unresolved, escalate to the Data Protection Board of India.

To exercise any right, contact our Grievance Officer (Section 9). We will respond within the timelines required by law.

8. Children's data

Centure is intended for users 18 and older. We do not knowingly process the personal data of children except as permitted under the DPDP Act with verifiable consent of a parent or lawful guardian. We do not undertake tracking, behavioral monitoring, or targeted advertising directed at children.

9. Grievance Officer & contact

If you have questions, requests, or complaints about your data, contact:

  • Grievance Officer: [Name]
  • Email: [grievance@centure.app]
  • Address: [Registered Address]

We will acknowledge and resolve grievances within the timelines prescribed under the DPDP Act (and in any case within 90 days). If you are not satisfied, you may approach the Data Protection Board of India.

10. Cookies & tracking

Our website may use cookies and similar technologies for essential functionality, security, and analytics. You can control cookies through your browser settings; disabling some may affect functionality.

11. Changes to this policy

We may update this policy from time to time. We will post the updated version with a new “Last updated” date and, where the change is significant, notify you through the Platform.

12. Governing law

This policy is governed by the laws of India, and any disputes are subject to the jurisdiction of the courts of [City], India.

This Privacy Policy is a template and does not constitute legal advice. Centure Capital. Investments are subject to market risk.