Privacy Policy

1. Introduction

Oleander Financial Technologies Private Limited ("Oleander", "we", "us", or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use Oleander - The Operating System for Life Goals.

By using our Services, you consent to the data practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Services.

2. Information We Collect

2.1 Information You Provide

We collect information that you voluntarily provide to us, including:

• Account Information: Name, email address, phone number, date of birth, PAN number, and other identification details
• Goal Information: Life goals, target amounts, timelines, risk tolerance, income, and financial objectives
• Profile Information: Goal preferences, financial objectives, and risk assessment responses
• Communication Data: Messages, feedback, and support inquiries you send to us
• Account Aggregator Data: Financial account information accessed through Account Aggregator framework (with your explicit consent)

2.2 Information Collected Automatically

When you use our Services, we automatically collect certain information, including:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, features used, time spent, goal tracking activities, and navigation paths
• Location Data: Approximate geographic location based on IP address
• Cookies and Tracking: Information collected through cookies, web beacons, and similar technologies

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Account Aggregator Network: Financial data from banks and financial institutions through RBI-regulated Account Aggregator framework
• Market data providers for securities pricing and information
• Identity verification services for KYC compliance
• Analytics providers for usage insights

3. How We Use Your Information

We use your information for the following purposes:

• Provide Services: To operate Goal OS, manage your account, and deliver goal tracking and financial planning services
• Personalization: To provide AI-powered recommendations tailored to your goals, risk profile, and financial situation
• Goal Tracking: To monitor your progress toward life goals and provide intelligent insights
• Communication: To send you goal updates, notifications, newsletters, and service communications
• Analytics: To analyze usage patterns, improve our Services, and develop new features
• Security: To detect, prevent, and respond to fraud, security threats, and illegal activities
• Compliance: To comply with legal obligations, including KYC, AML, and regulatory requirements
• Customer Support: To respond to your inquiries and provide technical assistance
• Research: To conduct research and analysis to improve our algorithms and services (using anonymized data)

4. Legal Basis for Processing (GDPR)

If you are in the European Economic Area (EEA), we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to provide our Services under our Terms of Service
• Consent: Where you have given explicit consent for specific processing activities
• Legitimate Interests: For our legitimate business interests, such as improving our Services and preventing fraud
• Legal Obligation: To comply with applicable laws and regulations

5. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

5.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Cloud hosting and infrastructure providers
• Payment processors
• Email and communication services
• Analytics and monitoring tools
• AI Processing Partners
• Identity verification services

5.2 Account Aggregator Data Sharing

When you connect your financial accounts through the Account Aggregator framework, we access your financial data only with your explicit consent and use it solely to provide goal tracking and financial planning services. This data is not shared with any third parties except as required by law.

5.3 Legal Requirements

We may disclose your information if required by law or in response to:

• Court orders, subpoenas, or legal processes
• Requests from government authorities or regulatory bodies (RBI, SEBI, Income Tax Department, etc.)
• Enforcement of our Terms of Service
• Protection of our rights, property, or safety, or that of others

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change in ownership or control.

6. Account Aggregator Data Handling

Goal OS integrates with the RBI-regulated Account Aggregator (AA) framework to help you track your financial progress toward your goals.

6.1 Consent-Based Access

We access your financial data only with your explicit consent through the AA framework. You have full control over:

• Which accounts to connect
• What data to share
• How long we can access the data
• The ability to revoke consent at any time

6.2 Data Usage

AA data is used exclusively for:

• Tracking your progress toward life goals
• Providing personalized financial insights
• Calculating goal achievement timelines
• Offering intelligent recommendations

6.3 Data Security

All AA data is encrypted in transit and at rest, stored securely in India, and never shared with third parties except as required by law. We follow RBI guidelines for AA data handling and retention.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience and collect usage data.

7.1 Types of Cookies We Use

• Essential Cookies: Required for the operation of Goal OS (e.g., authentication, security)
• Functional Cookies: Remember your preferences and goal settings
• Analytics Cookies: Help us understand how you use Goal OS (Google Analytics)
• Performance Cookies: Track goal progress and feature usage for optimization

7.2 Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may limit your ability to use some features of Goal OS. You can also manage your cookie preferences through our cookie consent banner.

8. Data Security

We implement bank-grade security measures to protect your information, including:

• Encryption of data in transit (TLS/SSL) and at rest (AES-256)
• Regular security audits and penetration testing
• Multi-factor authentication and access controls
• Employee training on data protection and security
• Compliance with RBI guidelines for financial data handling
• Regular backups and disaster recovery procedures
• Data residency in India for all sensitive financial information

While we strive to protect your information using industry-leading security measures, no system is completely secure. You acknowledge that you provide your information at your own risk.

9. Data Retention

We retain your personal information for as long as necessary to:

• Provide Goal OS services to you
• Comply with legal and regulatory requirements (typically 7 years for financial records)
• Resolve disputes and enforce our agreements
• Maintain business records and analytics (in anonymized form)

After the retention period, we will securely delete or anonymize your information. You may request deletion of your account at any time, subject to legal retention requirements. Account Aggregator data is retained according to your consent duration and RBI guidelines.

10. Your Privacy Rights

You have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal requirements)
• Portability: Request a copy of your data in a structured, machine-readable format
• Objection: Object to processing of your information for certain purposes
• Restriction: Request restriction of processing in certain circumstances
• Withdraw Consent: Withdraw consent for processing based on consent (including AA consent)
• Opt-Out: Opt out of communications at any time

To exercise these rights, please contact us at contact@olgo.in. We will respond to your request within 30 days.

11. Children's Privacy

Goal OS is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately, and we will delete such information.

12. International Data Transfers

Your information may be transferred to and processed in countries other than India for certain services (such as cloud infrastructure), but sensitive financial data remains in India. When we transfer your information internationally, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by regulatory authorities
• Adequacy decisions by relevant data protection authorities
• Binding Corporate Rules for intra-group transfers
• Compliance with RBI guidelines for cross-border data transfers

13. Third-Party Links and Services

Goal OS may contain links to third-party websites or integrate with third-party services (including Account Aggregator participants). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information to them.

14. Regulatory Compliance

Goal OS complies with applicable Indian regulations regarding data protection and financial services:

• RBI Guidelines: Account Aggregator framework compliance for financial data handling
• IT Act 2000: Data protection and cybersecurity compliance
• SEBI Regulations: Investment advisory and client data protection (when applicable)
• GDPR: For users in the European Economic Area

We maintain appropriate registrations and comply with all applicable regulatory requirements for financial technology services in India.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:

• Posting the updated Privacy Policy on our website
• Updating the "Last updated" date at the top of this page
• Sending you an email notification (for material changes)
• In-app notifications for significant changes affecting your rights

Your continued use of Goal OS after changes become effective constitutes your acceptance of the revised Privacy Policy.

16. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us: