Privacy Policy

1.1 Purpose of this Privacy Policy

This Privacy Policy describes how GROWUPP ABH SECUIRTY PRIVATE LIMITED ("Company", "we", "us", or "our") collects, uses, processes, stores, discloses, and protects personal information of users accessing or using the COINZII platform, including its website, mobile application, and related services (collectively referred to as the "Platform").

The Company is committed to ensuring the confidentiality, integrity, and security of user data and to maintaining transparency in its data handling practices.

1.2 Scope of Applicability

This Privacy Policy applies to:

• Individuals who register or use the COINZII platform;
• Visitors accessing the website or mobile application;
• Customers undergoing KYC or verification procedures;
• Individuals interacting with customer support;
• Business partners and service providers where applicable.

By accessing or using the Platform, users acknowledge and consent to the data practices described in this Privacy Policy.

1.3 Commitment to Data Protection

GROWUPP ABH SECUIRTY PRIVATE LIMITED recognizes that personal data protection is fundamental to maintaining user trust and regulatory compliance. Accordingly, the Company undertakes to:

• Collect only necessary and lawful data;
• Process information fairly and transparently;
• Use data strictly for legitimate business and regulatory purposes;
• Implement reasonable technical and organizational safeguards;
• Prevent unauthorized access, misuse, alteration, or disclosure of data.

1.4 Regulatory Alignment

The Company endeavors to align its data protection practices with applicable laws and regulatory expectations governing financial services, anti-money laundering compliance, and digital platforms. Where regulatory obligations require data retention or disclosure, such processing shall be conducted in accordance with lawful authority.

1.5 User Responsibility

Users are responsible for providing accurate and up-to-date information during registration and verification processes. Failure to provide accurate data may affect access to services.

2.1 Overview

GROWUPP ABH SECUIRTY PRIVATE LIMITED collects certain categories of personal and non-personal information to provide, operate, improve, and secure the COINZII platform, and to comply with applicable legal and regulatory obligations. The information collected may vary depending on how users interact with the Platform.

2.2 Information Provided by Users

When users register or interact with COINZII, the Company may collect the following information directly from users:

2.3 KYC & Verification Data

To comply with regulatory and AML obligations, the Company may collect:

• Government-issued identification documents
• Address proof documentation
• Source of funds declarations
• Video KYC recordings (where applicable)
• Risk assessment classification data

Such information is collected strictly for compliance, fraud prevention, and identity verification purposes.

2.4 Transaction & Usage Data

When users engage in activities on the Platform, the Company may collect:

• Deposit and withdrawal history
• Trade execution records
• Order timestamps
• Account balance history
• API interaction logs (if applicable)
• Customer support communication records

2.5 Technical & Device Information

To ensure platform security and performance, the Company may automatically collect:

• IP address
• Device type and operating system
• Browser type
• Device identifiers
• Login timestamps
• Location data (approximate, based on IP)

This information helps detect unauthorized access, suspicious activity, and system misuse.

2.6 Cookies & Tracking Technologies

The Platform may use cookies or similar technologies to:

• Maintain session integrity
• Enhance user experience
• Analyze platform usage patterns
• Improve security controls

Users may manage cookie preferences through browser settings, though disabling certain cookies may affect functionality.

2.7 Information from Third Parties

Where permitted by law, the Company may receive limited information from:

• KYC verification agencies
• Banking partners
• Payment service providers
• Fraud prevention databases
• Regulatory or compliance databases

Such data shall be used strictly for compliance and operational purposes.

2.8 Data Minimization Commitment

The Company endeavors to collect only such information that is:

• Necessary for service delivery;
• Required for regulatory compliance;
• Proportionate to risk management obligations;
• Relevant to fraud prevention and platform integrity.

3.1 Lawful & Legitimate Processing

GROWUPP ABH SECUIRTY PRIVATE LIMITED collects and processes personal information strictly for lawful, legitimate, and proportionate business purposes in connection with the operation of the COINZII platform. Personal data is processed only to the extent necessary to provide services, ensure regulatory compliance, manage risk, and maintain platform security.

3.2 Account Creation & Service Delivery

User information is collected and used to:

• Create and manage user accounts;
• Verify identity during registration;
• Facilitate deposits, withdrawals, and transactions;
• Execute trade instructions through integrated systems;
• Provide access to platform features and services;
• Maintain account history and transaction records.

Without such information, certain services may not be available.

3.3 Regulatory & Compliance Obligations

Personal data may be processed to:

• Conduct Customer Due Diligence (CDD);
• Perform Enhanced Due Diligence (EDD) where required;
• Comply with Anti-Money Laundering (AML) laws;
• Detect and prevent financial crime;
• File regulatory reports where legally mandated;
• Respond to lawful requests from authorities.

Processing for compliance purposes may continue even after account closure where required by law.

3.4 Fraud Prevention & Risk Management

Information may be used to:

• Detect suspicious or abnormal transactions;
• Prevent identity theft and account misuse;
• Identify unauthorized access attempts;
• Monitor system vulnerabilities;
• Enforce platform security controls.

Automated risk-scoring mechanisms may be used to enhance fraud detection.

3.5 Customer Support & Communication

The Company may use user information to:

• Respond to queries and support requests;
• Notify users regarding account activity;
• Provide service updates and compliance notices;
• Inform users of policy changes;
• Resolve disputes or complaints.

Communication may occur through email, SMS, in-app notifications, or other registered contact details.

3.6 Platform Improvement & Analytics

Data may be used in aggregated or anonymized form to:

• Analyze user behavior patterns;
• Improve user interface and functionality;
• Enhance system performance;
• Develop new features;
• Strengthen security infrastructure.

Such analysis shall not involve unauthorized disclosure of identifiable personal data.

3.7 Legal Enforcement & Protection

User information may be processed where necessary to:

• Enforce Terms & Conditions;
• Protect the rights, safety, and property of the Company;
• Prevent regulatory breaches;
• Defend against legal claims;
• Initiate or respond to legal proceedings.

3.8 No Unauthorized Commercial Exploitation

The Company does not sell personal data to third parties. Personal information shall not be used for unrelated commercial purposes without lawful basis or user consent, where required.