Privacy Policy

STOEX TRADING PLATFORM

P2 KOSHAYOJAN SERVICES PRIVATE LIMITED

P2 Koshayojan Services Private Limited is operating a marketplace in the name and style of STOEX (“STOEX “we”, “our”, or “us”) is committed to protecting your privacy. This Privacy Policy explains how your Personal Information is collected, used, and disclosed by us. This Privacy Policy applies to our website, APIs, mobile applications and its associated subdomains (collectively, our “Service(s)”). By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your Personal Information as described in this Privacy Policy and our Terms and Conditions available at https://www.stoex.io/terms-conditions 

1. Definitions & Key Terms

To help explain things as clearly as possible in this Privacy Policy, every time any of these terms
are referenced, are strictly defined as:

  • Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics, remember information about you such as your language preference or login information.
  • Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to P2 Koshayojan Services Private Limited, that is responsible for your information under this Privacy Policy.
  • Customer: refers to the company, organization or person that signs up to use our Service
  • Device: any internet connected device such as a phone, tablet, computer or any other device that can be used to visit our website, APIs, mobile applications and use the Services.
  • IP address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.
  • Personnel: refers to those individuals who are employed by the Company or are under contract to perform a service on behalf of one of the parties.
  • Personal Data/ Personal Information: shall have the same meaning as ascribed to it in Clause 9.2 of this Privacy Policy;
  •  Service: refers to the service provided by the Company as described in the relative terms (if available) and on this platform
  • Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you.
  • Website: STOEX Website, which can be accessed via this URL: www.stoex.io.
  • You: a person or entity that is registered onto the STOEX to use the Services.

2. ELIGIBILITY CRITERIA

2.1 By accessing the STOEX Trading Platform, you agree and warrant that:

  1. You are at least 18 years old;
  2. You are capable of entering and authorized to enter into a legally binding agreement;
  3. All information that you post on the STOEX Trading Platform or provide to us is true and accurate;
  4. You have the authority and capability to enter into this Agreement abiding by all the provisions of these Terms & conditions;
  5. You are not impersonating any person or entity;
  6. You are not subject to any financial sanctions, embargoes or other restrictive measures imposed by any regulated or law enforcement entities like SEBI, RBI, the UK Treasury, US Office of Foreign Assets Control (OFAC), United Nations Security Council, or any governmental or inter country authority (“Sanctions”) etc.;
  7. You are not currently suspended or banned by the Company from accessing the STOEX Trading Platform;
  8. You are not a politically exposed person;
  9. The jurisdiction in which you are situated does not prohibit you from using the platforms such as this STOEX Trading Platform;
  10. You are compliant of all the applicable laws which includes but are not limited to money laundering laws, taxation laws, securities laws, competition laws, foreign exchange laws and anti-terrorism laws

2.2 We also collect information from mobile devices for a better user experience, although these features are completely optional:

  1. I. Location (GPS): Location data helps to create an accurate representation of your interests, and this can be used to bring more targeted and relevant ads to potential customers.
  2. Phonebook (Contacts list): Your contacts list allows the platform to be much more easy to use by the user, since accessing your contacts from the app makes you save tons of time
  3. Camera (Pictures): Granting camera permission allows the user to upload any picture straight from the platform, you can safely deny camera permissions for this platform.
  4. Photo Gallery (Pictures): Granting photo gallery access allows the user to upload any picture from their photo gallery, you can safely deny photo gallery access for this platform.

3. USE OF INFORMATION

Your information will be visible to other users of the STOEX to facilitate communication between users. You agree that we may use your information in the following ways:
3.1 We use the information we collect about you to provide the Services to you, create a better, more personalized experience for you based on your individual usage habits, improve our marketing and promotional efforts, analyze site usage and disclose aggregated statistics, improve our content and service offerings, aid in our monetization efforts, and customize our STOEX content, layout and services. This may include migrating your information to other platforms owned by us. We also use the information we collect about you to review and investigate your activities or transaction on our STOEX, resolve disputes, troubleshoot problems, and enforce our Terms and Conditions.
3.2 We may use your correspondence with us, information posted by you for publication on our STOEX for promotional, sales or any use that we consider appropriate, whether submitted via email, or posted on our STOEX.
3.3 We may share the information that we collect, both personal and non-personal, with third parties such as advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you. We may also share it with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal information to our successors-in-interest
3.4 We may engage trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the website, database storage and management, e-mail management, storage marketing, credit card processing, customer service and fulfilling orders for products and services you may purchase through the website. We will likely share your Personal Information, and possibly some nonpersonal information, with these third parties to enable them to perform these services for us and for you.
3.5 We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the website in a shared location, and type of the device used to visit the website. They may aggregate information about our advertising and what you see on the website and then provide auditing, research and reporting for us and our advertisers.
3.6 We may also disclose personal and non-personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

4. How long do we keep Your Information?

4.1 Please note that the STOEX is being operated and managed from INDIA and is subject to the applicable laws of INDIA. While we have formulated this Privacy Policy in accordance with internationally recognized standards and regulations, particularly India’s Digital Personal Data Protection Act, 2023 (DPDPA) AND European Union’s General Data Protection Regulation (GDPR) which establishes a global benchmark for data protection and privacy; as an international user (located or situated outside of INDIA) certain other data privacy laws of your territory may be applicable on processing of your Personal Information. Nevertheless, when you access our Website and provide your Personal Information through any mode, whether through cookies or otherwise, you accept and acknowledge that your Personal Information is being processed in accordance with this Privacy Policy and that your Personal Information shall be stored in INDIA or in any other territory where the applicable provisions may be less stringent than the data privacy laws of your territory.  

4.2 We shall store and retain your Personal Information as long as it is required for the fulfilment of Services set out in this Privacy Policy or as required in accordance with the applicable data privacy laws, whichever is later (“Storage Period”). After the processing is complete or in case you withdraw the consent given for such processing, the Personal Information that is stored and retained with us shall be either deleted or anonymized in accordance with the applicable laws. 

4.3 However, it is to be noted that the STOEX employ smart contracts that are executed on blockchain technology which is immutable and hence cannot be altered, amended or deleted unless allowed in the smart contract. If you use the STOEX, you are consenting to allow certain information such as account transactions, wallet entries etc. to be cryptographically transmitted and stored on that blockchain that may be permanently stored on such blockchain.

5. SECURITY & RELIABILITY

We take reasonable security measures to protect Personal Information against loss, misuse, unauthorized or accidental access, disclosure, alteration and destruction. We have implemented policies and maintained appropriate technical, physical, and organizational measures and followed industry practices and standards in adopting procedures for securing and implementing systems designs and protecting Personal Information from unauthorized access, improper use, disclosure and alteration.

6. THIRD PARTY WEBSITES

Our STOEX may contain links to third-party websites which are not our authorized Third Parties. When you click on a link to any other website or location, you will leave our STOEX and go to another site, and another entity may collect Personal Information from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your Personal Information after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

7. CHILDREN’S PRIVACY

STOEX does not allow persons under 18 to register for any Service, and we do not knowingly collect any personally identifiable information from persons under the age of 18. If you are aware of someone under the age of 18 using our Services, please contact us immediately by contact form.

8. USER ACCESS TO PERSONAL INOFRMATION

8.1 You can modify all of your Personal Information and your privacy preferences by accessing the “Account” section of this website/application at any given time. Users are encouraged to put in a diligent effort in updating their Personal Information from time to time, to continue the flow of seamless counselling and services.
8.2 Subject to the limitation of immutability of data transmitted on blockchains, you may at any point of time, withdraw your consent given to us to process your Personal Information, pursuant to which, you shall not be able to access or use any service provided on the STOEX and no further data of yours shall be collected or processed by us. However, the Personal Information already in our possession shall be stored and retained till the Storage Period. To withdraw your consent, please write to us at compliance@stoex.io.

9. Information about General Data Protection Regulation (GDPR)

We may be collecting and using information from you if you are from the European Economic Area (EEA), and in this section of our Privacy Policy we are going to explain exactly how and why is this data collected, and how we maintain this data under protection from being replicated or used in the wrong way

9.1 What is GDPR?

GDPR is an EU-wide privacy and data protection law that regulates how EU residents’ data is protected by companies and enhances the control the EU residents have, over their Personal Data.The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU residents. Our customers’ data is important irrespective of where they are located, which is why we have implemented GDPR controls as our baseline standard for all our operations worldwide

9.2 What is Personal Data/Information?

Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used on its own, or in combination with other pieces of information, to identify a person. Personal data extends beyond a person’s name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP addresses, physical address, sexual orientation, and ethnicity. The Data Protection Principles include requirements such as:
  • Personal Data collected must be processed in a fair, legal, and transparent way and should only be used in a way that a person would reasonably expect.
  • Personal Data should only be collected to fulfil a specific purpose and it should only be used for that purpose. Organizations must specify why they need the Personal Data when they collect it.
  • Personal Data should be held no longer than necessary to fulfil its purpose.
  • People covered by the GDPR have the right to access their own Personal Data. They can also request a copy of their data, and that their data be updated, deleted, restricted, or moved to another organization.

9.3 Individual Data Subject's Rights - Data Access, Portability and Deletion

We are committed to helping our customers meet the data subject rights requirements of GDPR. STOEX processes or stores all Personal Data in fully vetted, DPA compliant vendors. We do store all conversation and Personal Data for up to 6 years unless your account is deleted. In which case, we dispose of all data in accordance with our Terms of Service and Privacy Policy, but we will not hold it longer than 60 days. We are aware that if you are working with EU customers, you need to be able to provide them with the ability to access, update, retrieve and remove Personal Data. We got you! We’ve been set up as self-service from the start and have always given you access to your data and your customers data. Our customer support team is here for you to answer any questions you might have about working with the API.

9.4 Rights of User subject to GDPR

If you are a user who is subject to the GDPR, you have the right to:

  • Request an access to your Personal Information collected and processed by us. You may also request a copy of your Personal Information which you shall receive in a structured, standard, and properly formatted manner. You may also request transmission of your Personal Information to another person responsible;
  • Request a rectification of the incorrect Personal Information (if any) or completion of any incomplete Personal Information stored with us;
  • Subject to the data transmitted on blockchain at your consent, request deletion or removal of any of your particular or complete Personal Information stored with us;
  • Dispute, object or request a restriction on processing of your Personal Information collected by us; and
  • Withdraw your consent for processing of your Personal Information at any time in case you have previously given us your consent in this regard.
  • If you wish to exercise any of the rights mentioned above or any other legal rights you have under the GDPR regarding the collection, storage and processing of your Personal Information, you may write to us at compliance@stoex.io.

10. INTERNATIONAL USERS

The STOEX is being operated and managed from INDIA and is subject to the applicable laws of INDIA (Digital Personal Data Protection Act, 2023). As an international user (located or situated outside of INDIA) certain other data privacy laws of your territory may be applicable on processing of your Personal Information. However, when you access our STOEX and provide your Personal Information through any mode whether through cookies or otherwise, you accept and acknowledge that your Personal Information is being processed in accordance with this Privacy Policy and the Personal Information may be processed and stored in INDIA or other countries where the applicable provisions may be less stringent than the data privacy laws of your territory.

11. COOKIES

STOEX uses “Cookies” to identify the areas of our website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to enhance the performance and functionality of our website but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the website as we would not be able to remember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personally Identifiable Information in Cookies.

12. AMENDMENT TO THIS POLICY

Any changes to be made to these Privacy Policy, will be effective once published on the STOEX website or upon release to the users of STOEX Trading Platform. Your continued used of the STOEX Trading Platform or the services available therein is considered your acceptance of such amended terms. If you do not agree to any amendments in these Privacy Policy, you must stop using the STOEX Trading Platform effective immediately. A frequent viewing of these Privacy Policy is recommended for a better understanding of these Privacy Policy that apply to access and use of the STOEX Trading Platform.

13. COMPLIANCE/GRIEVANCE OFFICER

13.1 All your questions, discrepancies and grievances with respect to processing of Personal Information shall be made to the (Grievance Officer) at compliance@stoex.io.
13.2 The Grievance Officer shall redress the grievances of the users and other individuals expeditiously and in any event within the period prescribed under law. In case of any queries regarding the content, interpretation, implications of this Policy, you may contact the Grievance Officer at compliance@stoex.io.

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