Privacy Policy
Smooth Money Financial Technologies Pvt Ltd (“Smooth Money”, “we”, “our”, or “us”) is a financial wellness and insights product designed to help users understand and improve their money-related habits. This Privacy Policy explains how we collect, use, share, retain, and protect personal information in the current release of our mobile applications, website, and related services (collectively, the “Services”).
This Privacy Policy applies to the current iOS and Android releases of Smooth Money, our website, and our support interactions. Unless expressly stated otherwise below, this Privacy Policy does not describe future, optional, or not-yet-launched product features, integrations, permissions, or regulated transaction flows. If we introduce new optional integrations, permissions, or materially different data practices in a future release, we will update this Privacy Policy before launching those changes.
1. Scope of This Policy
This Privacy Policy covers information collected directly by Smooth Money through:
- the Smooth Money mobile applications;
- the Smooth Money website;
- account registration and profile setup;
- customer support and user communications; and
- analytics, diagnostics, and security monitoring related to the Services.
2. Information We Collect
We collect only the information reasonably necessary to operate, secure, and improve the Services.
A. Account and Identity Information
We collect identifiers and account-related information such as:
- your user ID;
- your name, email address, and authentication-related identifiers;
- profile information you choose to provide; and
- information necessary to create, maintain, and secure your account.
B. Information You Provide in the App
We collect information you submit directly in the Services, such as:
- goals, preferences, and onboarding responses;
- profile details;
- support requests, feedback, and communications with us; and
- other information you voluntarily choose to provide within the current functionality of the Services.
C. Product Interaction and Usage Data
We collect information about how users interact with the Services, such as:
- app screens viewed;
- navigation events;
- feature usage;
- engagement with in-app flows and product features; and
- certain in-app interaction events, such as taps on buttons, controls, and other app elements.
We use this information for analytics, service improvement, product development, debugging, and operational monitoring.
D. Crash, Performance, and Diagnostic Data
We collect technical information necessary to maintain the reliability, security, and performance of the Services, including:
- crash logs and error reports;
- app performance and stability metrics;
- app lifecycle and operational telemetry; and
- other diagnostic and technical data used for troubleshooting, fraud prevention, abuse detection, and platform integrity.
E. Information Linked to Your Account
Some analytics, diagnostic, security, and support-related data may be associated with your account or user identifier, where reasonably necessary to provide app functionality, secure the Services, investigate issues, or improve product performance.
F. App Privacy Categories
We do not use the Apple Identifier for Advertisers (IDFA), the Google Advertising ID (GAID), or any other cross-app or cross-site tracking identifiers. We do not track users across apps or websites owned by other companies as defined by Apple’s App Tracking Transparency framework or Google’s equivalent policies.
3. Information We Do Not Collect
The current release of Smooth Money does not access, collect, or process the following categories of information through the app:
- Gmail or Outlook inbox data;
- SMS messages;
- bank account data or bank statements;
- Account Aggregator data;
- broker, mutual fund, or other external financial account data imported through third-party APIs;
- your contacts or address book;
- precise device location;
- Apple Identifier for Advertisers (IDFA) or any cross-app or cross-site tracking identifiers; and
- Google Advertising ID (GAID) or Android advertising identifiers.
We do not intentionally use analytics or diagnostic tools to capture passwords, authentication secrets, or sensitive financial information entered into the app.
We do not track users across apps or websites owned by other companies. We do not use Apple’s App Tracking Transparency (ATT) framework to request tracking permission because we do not engage in tracking as defined by Apple or Google.
The current release does not enable session replay.
4. How We Use Information
We use personal information for the following purposes:
- to create, maintain, and secure user accounts;
- to provide the core functionality of the Services;
- to personalise the app experience based on goals, preferences, and information you provide;
- to generate insights, suggestions, summaries, and educational content within the Services;
- to monitor usage patterns, feature engagement, and in-app interactions;
- to fix bugs, investigate incidents, improve performance, and improve the Services;
- to detect, prevent, and address fraud, abuse, misuse, or security issues;
- to respond to support requests and communicate with users; and
- to comply with legal, regulatory, accounting, or reporting obligations.
5. Legal Basis and Consent
We process your personal data on the following legal bases under the Digital Personal Data Protection Act, 2023:
- Consent: When you create an account, you are presented with this Privacy Policy and asked to provide your informed, specific consent to the collection and processing of your personal data for the purposes described herein. You may withdraw your consent at any time through Settings > Account > Privacy or by contacting us at privacy@smooth.money.
- Voluntary provision for specified purpose: Where you voluntarily provide personal data for a specified purpose (such as submitting a support request), we process that data for the purpose for which it was provided, in accordance with applicable law.
Consent obtained through the app is specific to each processing category. You are not required to consent to any processing that is not necessary for the core functionality of the Services.
6. Automated Processing and Recommendations
Smooth Money may use automated systems, including rules-based logic and machine learning or artificial intelligence tools, to generate in-app insights, recommendations, summaries, and educational content based on the information you provide and your use of the Services.
These outputs are designed to support financial awareness and product functionality. They are provided for informational and educational purposes only and do not constitute financial, investment, tax, legal, or accounting advice.
You should independently evaluate any recommendation before acting on it and, where appropriate, consult a qualified professional.
7. Third-Party Service Providers and SDKs
We do not sell personal information. We do not use personal information for third-party advertising, data brokerage, or cross-app or cross-service behavioural profiling or tracking.
We may share information only in the following limited circumstances:
- Service Providers: with vendors and service providers that help us operate the Services, such as hosting, authentication, analytics, crash reporting, diagnostics, customer support, and communications providers, subject to contractual confidentiality and data protection obligations.
- Regulatory and Transaction Partners: if and when you use Smooth Money features that enable mutual fund transactions, distributor-led onboarding, or regulatory compliance workflows, with KYC Registration Agencies, Registrar and Transfer Agents, MF Utilities India Pvt Ltd, and Asset Management Companies, solely for the purpose of processing mutual fund transactions and complying with applicable SEBI regulations and AMFI guidelines.
- Legal and Compliance: where required by law, regulation, court order, legal process, or lawful governmental request, or where disclosure is necessary to protect rights, safety, or the integrity of the Services.
- Corporate Transactions: in connection with a merger, acquisition, financing, reorganisation, sale of assets, or similar transaction, subject to applicable confidentiality and legal requirements.
We require that all third-party service providers maintain data protection standards at least equivalent to those described in this Privacy Policy and applicable law, including the Digital Personal Data Protection Act, 2023.
8. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
In general:
- account and profile information is retained for as long as your account remains active and for a reasonable period thereafter as necessary for compliance, dispute resolution, fraud prevention, and security;
- analytics, crash, performance, and diagnostic data is retained only for as long as reasonably necessary for operational monitoring, troubleshooting, security review, and product improvement; and
- support records and communications may be retained for a reasonable period to address follow-up issues, improve support quality, and comply with legal obligations.
We may retain de-identified or aggregated information for longer periods where permitted by law.
9. Account Deletion and Your Choices
You may request deletion of your Smooth Money account and associated personal information at any time.
You can do this:
- through the in-app account deletion flow located at: Settings > Account > Delete Account; or
- by contacting us at privacy@smooth.money.
Upon receiving a valid deletion request, we will delete or anonymise your personal information within 30 days, except where we are required to retain certain information to comply with law, prevent fraud, resolve disputes, enforce agreements, or maintain security and platform integrity.
Subject to applicable law, you may also contact us to:
- access or correct certain personal information;
- request a copy of certain information associated with your account; or
- withdraw consent where processing is based on consent.
10. Data Security
We use reasonable technical, administrative, and organisational safeguards designed to protect personal information from unauthorised access, disclosure, alteration, loss, or misuse.
These safeguards include encryption in transit (TLS), access controls, authentication controls, logging, monitoring, and vendor security review processes.
No method of transmission or storage is completely secure. As a result, we cannot guarantee absolute security.
11. Data Breach Notification
In the event of a personal data breach, we will:
- promptly notify the Data Protection Board of India, providing details of the breach, the personal data affected, and the remedial measures taken or proposed;
- promptly notify affected users, providing sufficient information for them to take protective action; and
- take reasonable steps to contain and remediate the breach.
Notification will be made in accordance with the timelines and procedures prescribed under the Digital Personal Data Protection Act, 2023, and the rules made thereunder.
12. Children’s Privacy
The Services are not directed to children under the age of 18, and we do not knowingly collect personal information from individuals under 18.
If you believe a child has provided personal information to us, please contact us at privacy@smooth.money so that we can review the issue and take appropriate action.
13. Data Storage and International Transfers
Your information is primarily stored on servers operated by Amazon Web Services (AWS). AWS infrastructure used by Smooth Money may include servers located in India and other regions.
Where your information is transferred to or processed in a jurisdiction outside India, we ensure that appropriate safeguards are in place in accordance with applicable data protection laws, including the Information Technology Act, 2000, and the Digital Personal Data Protection Act, 2023, as applicable.
14. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes to the Services, our data practices, legal requirements, or platform rules. When we make material changes, we will update the “Last Updated” date and, where required, provide additional notice through the app, website, or email.
If we introduce new categories of personal data collection, device permissions, third-party integrations, or regulated financial transaction features, we will update this Privacy Policy before those changes go live and, where required by law, obtain fresh consent or provide additional notice.
15. Grievance Officer and Data Protection Board
In accordance with the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, and the rules made thereunder, the name and contact details of the Grievance Officer are as follows:
- Name: Kumar Sarvendu Bindeshwar Singh
- Designation: Grievance Officer
- Email: privacy@smooth.money
The Grievance Officer shall address any complaints or concerns regarding the processing of personal information within 30 days of receipt.
If you are not satisfied with the Grievance Officer’s response, or if your grievance is not resolved within 30 days, you may file a complaint with the Data Protection Board of India in accordance with the procedures prescribed under the Digital Personal Data Protection Act, 2023, and the rules made thereunder.
16. Financial Services and Regulatory Disclosures
Smooth Money Financial Technologies Pvt Ltd is registered as a mutual fund distributor with the Association of Mutual Funds in India (AMFI).
- AMFI Registration Number (ARN): ARN-349480
- CIN: U62099MH2025PTC458584
The disclosures in this section apply only if and when Smooth Money offers mutual fund distribution, transaction execution, or related regulatory onboarding features to you in a live release of the Services.
Smooth Money operates as an AMFI-registered Mutual Fund Distributor. We are not registered as an Investment Adviser with the Securities and Exchange Board of India (SEBI). Any insights, recommendations, or suggestions provided through the Services are for informational and educational purposes only and do not constitute investment advice as defined under the SEBI (Investment Advisers) Regulations, 2013.
Mutual fund investments are subject to market risks. Please read all scheme-related documents carefully before investing.
KYC and Investor Data
If and when you invest in mutual fund schemes through our platform, we will collect and process Know Your Customer (KYC) information as required under SEBI regulations and AMFI guidelines. This may include:
- PAN (Permanent Account Number) for identity verification;
- identity and address documents as required under SEBI KYC norms; and
- information required for CKYC (Central KYC) registration and verification.
This data may be shared with KYC Registration Agencies (KRAs), Registrar and Transfer Agents (RTAs), MF Utilities India Pvt Ltd (MFU), and the relevant Asset Management Companies (AMCs) solely for the purpose of processing your mutual fund transactions and complying with regulatory requirements.
Commission Disclosure
If Smooth Money enables mutual fund distribution through the Services, the schemes offered through our platform may be Regular Plan mutual fund schemes for which we receive commissions from Asset Management Companies as the distributor.
Details of commissions received or receivable by us for different schemes of various mutual funds are available at:
https://www.amfiindia.com/distributor-corner/commission-details
Transaction Data Flow
If mutual fund transaction features are enabled, transactions initiated through the Services will generally follow this data flow:
- Smooth Money (as distributor) collects your investment instructions and KYC data;
- this data is transmitted to MF Utilities India Pvt Ltd (MFU) for order processing;
- MFU routes the order to the relevant Asset Management Company (AMC); and
- the AMC and its Registrar and Transfer Agent (RTA) process the transaction and maintain investor records.
Each entity in this chain processes your data in accordance with applicable SEBI regulations, AMFI guidelines, and its own privacy policy.
17. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:
Smooth Money Financial Technologies Pvt Ltd
- Email: privacy@smooth.money
- Support: support@smooth.money
- Website: https://smooth.money
Address: 211, Sabarmati, Lokgram, Kalyan East, Dwarli, Kalyan, Thane – 421306, Maharashtra, India