Privacy Policy

Last Updated: April 18, 2025

1. INTRODUCTION

This Privacy Policy ("Policy") is issued by Purple Pixel Private Limited, a company incorporated under the Companies Act, 2013, having its registered office at HD-276, WeWork, Hebbal, Bengaluru, India (referred to as "Company," "Feo," "we," "our," or "us").

This Policy governs how we collect, process, store, use, disclose, and protect Personal Data belonging to any natural person ("User," "you," or "your") who accesses or uses our website https://feo.io, desktop application, mobile application, software applications, and related platforms (collectively, the "Online Platform").

This Privacy Policy forms part of and should be read along with our Terms of Service ("TOS"). By using our Online Platform, you consent to the practices described in this Policy.

For the purposes of this Policy, "Personal Data" means any information relating to an identified or identifiable natural person. This does not include anonymized data or publicly available information that has not been combined with non-public Personal Data.

IMPORTANT NOTICE: Our Online Platform and services are not intended for minors below the age of 18 years or individuals who are legally incapacitated. We do not knowingly collect Personal Data from such individuals.

2. GENERAL PROVISIONS

   1. Amendments to Privacy Policy

   We reserve the right to modify this Privacy Policy at our discretion. Any changes will be effective immediately upon posting on the Online Platform. Material changes will be communicated through appropriate channels. The "Last Updated" date will reflect the most recent modifications.

Your continued use of our Online Platform following any changes constitutes your acceptance of the modified Privacy Policy. If you disagree with the revised Policy, you must discontinue using our services.

3. COLLECTION OF INFORMATION

   1. Categories of Information Collected

      We may collect and process the following categories of data about you:

      1. Identity and Account Information
         1. Basic personal identifiers (name, username, account ID, date of birth, gender, nationality)
         2. Government-issued identification documents
         3. Tax identification information
         4. Additional information you voluntarily provide
      2. Contact Information
         1. Residential, correspondence, and business addresses
         2. Email addresses
         3. Telephone numbers
         4. Other communication channels
      3. Financial and Transaction Information
         1. Bank account details
         2. Payment card information
         3. Digital wallet and cryptocurrency wallet addresses
         4. Transaction history
         5. Billing records
         6. Credit information
         7. Source of funds declarations
      4. Technical and Usage Information
         1. IP address
         2. Device and browser information
         3. Mobile device identifiers
         4. Browsing patterns and activity
         5. Search terms and interactions
         6. Time zone and language settings
         7. Geolocation data
         8. Telemetry data
      5. Cookies and Tracking Technologies
         1. Essential cookies for basic functionality
         2. Performance cookies to understand usage
         3. Functional cookies for enhanced features
         4. Targeting/advertising cookies
      6. Customer Service and Communications
         1. Support communications and recordings
         2. Feedback and survey responses
         3. Correspondence related to inquiries and disputes
      7. Third-Party Information
         1. Information from business partners and service providers
         2. Publicly available information
         3. Information from regulatory bodies
      8. Compliance and Risk Management
         1. Anti-money laundering (AML) and counter-terrorist financing (CTF) information
         2. Risk assessment and fraud prevention data
         3. Records of acceptances and consents

   2. Methods of Collection

      1. Direct Collection: Information you voluntarily provide when registering, completing forms, communicating with us, or using our services.
      2. Automated Collection: Information collected through cookies, server logs, analytics tools, and mobile device interactions.
      3. Third-Party Collection: Information received from service providers, identity verification services, credit bureaus, public databases, and social media platforms.

   3. Legal Basis for Collection:

      We collect and process your Personal Data based on one or more of the following legal grounds:

      1. Contractual necessity
      2. Legal obligation
      3. Legitimate interests
      4. Consent
      5. Vital interests
      6. Public i nterest

4. USE OF INFORMATION

We use your Personal Data for various purposes, including:

1. Account Creation and Management

   1. Creating and maintaining your user account

      2. Verifying your identity and authenticating access
      3. Customizing your user experience
      4. Managing subscription preferences
      5. Responding to account-related inquiries

   2. Service Provision and Transaction Processing

      1. Facilitating and completing transactions
      2. Providing access to features and services
      3. Maintaining transaction records
      4. Processing payments and financial transactions
      5. Sending transaction confirmations
      6. Managing digital assets
      7. Enabling interoperability with third-party services

   3. Customer Support and Communication

      1. Providing technical assistance and support
      2. Responding to inquiries and feedback
      3. Resolving disputes
      4. Communicating important updates
      5. Conducting customer satisfaction surveys
      6. Maintaining communication records

   4. Compliance and Risk Management

      1. Conducting Know Your Customer (KYC) verification
      2. Performing due diligence
      3. Complying with AML and CTF requirements
      4. Meeting tax reporting obligations
      5. Detecting and preventing fraud
      6. Assessing and managing risks
      7. Conducting audits
      8. Responding to legal processes

   5. Security and Platform Integrity

      1. Authenticating identity and verifying access
      2. Monitoring for suspicious activities
      3. Implementing technical safeguards
      4. Securing accounts and data
      5. Conducting security assessments
      6. Investigating security incidents
      7. Enforcing our Terms of Service

   6. Product Development and Enhancement

      1. Developing and improving services
      2. Analyzing usage patterns
      3. Conducting research and development
      4. Measuring performance
      5. Troubleshooting issues
      6. Creating analytical data sets

   7. Marketing and Communication

      1. Sending information about products and services
      2. Delivering personalized content
      3. Notifying about updates
      4. Inviting participation in promotions
      5. Communicating about partnerships
      6. Measuring marketing effectiveness
      7. Managing customer relationships

   8. Business Operations and Strategic Planning

      1. Business planning and forecasting
      2. Market analysis
      3. Evaluating business opportunities
      4. Managing corporate transactions
      5. Maintaining business records
      6. Preparing reports
      7. Protecting legal rights

2. DISCLOSURE OF INFORMATION

   1. Categories of Recipients

   We may disclose your Personal Data to:

   1. Affiliated Entities: Our parent company, subsidiaries, joint ventures, and other affiliated entities.

   2. Service Providers and Business Partners: Third parties who perform services on our behalf, including payment processors, hosting providers, customer support, marketing partners, analytics vendors, security providers, identity verification services, and professional advisors.

   3. Third-Party Digital Asset Service Providers: Digital asset service providers, custodians, exchanges, and financial institutions necessary to facilitate transactions.

   4. Legal and Regulatory Authorities: Government authorities, regulatory agencies, law enforcement, courts, and public authorities when required by law or necessary to protect rights and safety.

   5. Professional Advisors: Lawyers, bankers, auditors, and insurers providing professional services.

   6. Corporate Transaction Participants: Parties involved in mergers, acquisitions, restructuring, or other ownership changes.

   7. Third Parties with Your Consent: Entities with whom you have directed or consented to share your information.

   8. Other Users: Other users of our Online Platform when necessary for certain features.

   9. Third-Party Websites and Services

   Our Online Platform may contain links to third-party websites not owned or controlled by us. This Policy applies only to our Online Platform. We assume no responsibility for third-party privacy practices. We encourage you to review the privacy policies of every website you visit.

   3. Cross-Border Transfers of Personal Data

   Your Personal Data may be transferred to countries other than your country of residence. By using our Online Platform, you consent to such transfers. We implement appropriate safeguards to protect your data during international transfers.

   4. Aggregated and Non-Personal Data

   We may use, share, and disclose aggregated, anonymized, and non-personal information for various business purposes, including analytics, research, and marketing.

3. CONSENT MANAGEMENT

   1. Provision of Consent

   By using our Online Platform, you consent to the collection, use, processing, disclosure, and transfer of your Personal Data as described in this Policy. Your consent is provided voluntarily and can be withdrawn as described below.

   2. Withdrawal of Consent

   You may withdraw your consent at any time by:

   1. Disabling or deleting your account
   2. Submitting a request to our Data Protection Officer
   3. Following unsubscribe instructions in communications

   Upon withdrawing consent, we will cease processing your Personal Data for those purposes, though we may retain data needed for legal compliance or other legitimate purposes.

   3. Consequences of Not Providing Personal Data

   If you choose not to provide requested Personal Data, we may be unable to:

• Create or maintain your account
• Provide access to our services
• Process your transactions
• Respond to your inquiries
• Send important information

7. ASSIGNMENT AND TRANSFER

   We may assign our rights and obligations under this Policy to affiliated entities, successors, service providers, or other entities. We will take reasonable steps to ensure continued protection of your Personal Data following such transfers.

8. DATA SECURITY

   1. Security Measures

   We implement reasonable technical, organizational, and physical safeguards to protect your Personal Data, including encryption, access controls, security assessments, employee training, physical security, and incident response procedures.

   2. Security Limitations

   Despite our security measures, no method of transmission or storage is 100% secure. You acknowledge that any transmission of Personal Data is at your own risk. We disclaim any guarantee of absolute security.

   3. Your Security Responsibilities

   You play an important role in protecting your Personal Data. We recommend using strong passwords, enabling multi-factor authentication, being vigilant against phishing, maintaining confidentiality of credentials, and using secure connections.

9. DATA RETENTION

   1. Retention Period

   We retain your Personal Data only as long as necessary to fulfill the purposes for which it was collected, including legal, regulatory, accounting, or reporting requirements. Different types of data may have different retention periods based on purpose and applicable laws.

   2. Data Deletion and Anonymization

   Upon expiration of the retention period, we will securely delete or anonymize your Personal Data. We may retain certain data for legitimate purposes such as legal compliance, dispute resolution, or business interests.

10. YOUR RIGHTS AND CHOICES

    1. Overview of Your Rights

Subject to applicable laws, you may have the following rights:

• Right to Access: Request access to your Personal Data and details about its processing.

• Right to Rectification: Request correction of inaccurate or incomplete data.

• Right to Erasure: Request deletion of your Personal Data under certain conditions.

• Right to Restriction of Processing: Request limiting how we use your data in certain circumstances.

• Right to Data Portability: Receive your data in a structured, machine-readable format.

• Right to Object: Object to processing based on legitimate interests, direct marketing, or research.

• Right to Withdraw Consent: Withdraw consent previously provided.

• Right to Lodge a Complaint: File a complaint with a supervisory authority.

• Right to Non-discrimination: Not be subjected to discrimination for exercising privacy rights.

• Right to Nominate a Representative: Authorize someone to exercise rights on your behalf.

  2. Exercise of Rights

  To exercise your rights, contact our Data Protection Officer using the information in Section 15. We may require identity verification before processing your request. We aim to respond to all legitimate requests within one month.

  3. Limitations on Rights

  Your rights may be subject to limitations under applicable laws, including legal obligations, technical limitations, and legitimate interests of ourselves or third parties.

11. MARKETING COMMUNICATIONS

    1. Marketing and Promotional Material

    We may use your Personal Data to send marketing communications through various channels. You can opt out at any time.

    2. Opting Out of Marketing Communications

    You can opt out by following unsubscribe instructions, adjusting account settings, or contacting our Data Protection Officer. Even after opting out, you may still receive non-marketing communications such as transaction confirmations and service updates.

12. CHILDREN'S PRIVACY

Our Online Platform is not directed to children under 18. We do not knowingly collect data from minors. If we discover we have collected data from a minor, we will delete it promptly.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Policy periodically to reflect changes in practices or laws. Material changes will be notified through appropriate channels. Your continued use after such changes constitutes acceptance of the revised Policy.

14. GOVERNING LAW AND DISPUTE RESOLUTION

This Policy is governed by the laws of India. Any disputes shall first be addressed through good-faith negotiations, followed by arbitration in Bengaluru, India, if necessary. The arbitration shall be conducted in English by a sole arbitrator in accordance with the Arbitration and Conciliation Act, 1996.

15. CONTACT INFORMATION

If you have questions about this Privacy Policy, please contact our Data Protection Officer:

Email: [email protected]

Postal Address:
Data Protection Officer
Purple Pixel Private Limited
HD-276, WeWork, Hebbal
Bengaluru, India

16. DEFINITIONS

Key terms used in this Policy:

• Applicable Law: Laws, regulations, and requirements applicable to this Policy.
• Consent: Freely given, specific agreement to data processing.
• Cookies: Small text files stored on devices to remember preferences.
• Data Fiduciary: Entity determining the purpose and means of processing Personal Data.
• Data Processor: Entity processing Personal Data on behalf of a Data Fiduciary.
• KYC: Know Your Customer verification process.
• Online Platform: Our website, applications, and related platforms.
• Personal Data: Information relating to an identified or identifiable person.
• Processing: Any operation performed on Personal Data.
• Sensitive Personal Data: Special categories of data including financial, health, biometric data, etc.
• Third Party: Any person or entity other than you, us, or our affiliates.

17. MISCELLANEOUS

• Severability: If any provision is found invalid, the remaining provisions remain in effect.
• Waiver: No failure to exercise rights constitutes a waiver of those rights.
• Entire Agreement: This Policy constitutes the entire agreement regarding your Personal Data.
• Force Majeure: We are not liable for failures due to circumstances beyond our control.
• Electronic Communications: You consent to receive electronic communications related to this Policy.
• No Third-Party Beneficiaries: This Policy benefits only the parties and their successors.
• Survival: Provisions that should naturally survive termination will continue to apply.