Who we are
SMG Horizon Services Private Limited (“SMG”, “we”) decides how and why your personal data is processed for the Service. Contact: info@smghorizon.com. Grievance officer: Noushad Nellanchery, info@smghorizon.com.
Data we collect
| Category | Examples |
|---|---|
| Contact & delivery | Name, mobile number, email, postal and delivery addresses |
| Identity / KYC | PAN, officially valid document details, date of birth, photograph or liveness check results, as required by law |
| Payment metadata | Order and transaction IDs, amount, payment method type, status and gateway reference. We do not receive full card numbers, CVV or UPI PINs. |
| Bank payout | Bank account number, IFSC and account-holder name verification result |
| Transactions | Quotes, purchases, allocations, invoices, sell-backs and payouts |
| Device & security | Device identifiers, IP address, app version, login and security logs |
| Analytics | Aggregated usage information, if and only if analytics are enabled and disclosed below |
| Support | Messages, call notes and attachments you send us |
What we never ask for
We will never ask you for your OTP, UPI PIN, card CVV, net-banking password or app password, and our systems are designed not to collect them.
Why we use your data
- To open and operate your account and provide quotes, purchases, coin delivery, allocation, custody records, sell-back and payouts.
- To verify identity and bank accounts and meet KYC, anti-money-laundering, tax and record-keeping obligations.
- To prevent and investigate fraud and keep the Service secure.
- To issue invoices and communicate with you about your transactions and the Service.
- To handle support requests and complaints.
- With your separate consent, to send marketing messages (you can withdraw consent at any time).
Legal basis and consent
We process personal data with your consent, or where processing is necessary to provide the Service you have requested, to comply with law, or for other purposes permitted by law. Where we rely on consent you can withdraw it, but this may mean we can no longer provide some or all of the Service. Withdrawal does not affect data we must keep by law.
Who we share data with
- Service providers acting for us: payment gateways, KYC and bank-verification providers, cloud hosting, messaging and support tools, under contracts requiring confidentiality and security.
- Gold supply and custody partners, to the extent needed to procure, allocate and hold your gold.
- Logistics partners, who receive your name, delivery address and mobile number to deliver coin orders and verify your identity at handover.
- Professional advisers such as auditors and lawyers.
- Authorities where required by law, such as tax authorities, the Financial Intelligence Unit or law enforcement.
We do not sell your personal data.
Cookies and analytics
This website currently uses no advertising cookies, no third-party analytics and no tracking pixels. If we introduce any, we will update this section and, where required, ask for your consent first.
Security
We use measures such as encryption in transit, access controls, logging and vendor due diligence. No system is completely secure. If a personal data breach occurs that affects you, we will notify you and the relevant authorities as required by law.
Retention
We keep personal data only as long as needed for the purposes above, and for the periods required by law (for example KYC and transaction records under anti-money-laundering and tax law). We then delete or anonymise it.
Your rights
Subject to applicable law, you may request access to a summary of your personal data, correction or completion of inaccurate data, erasure of data we no longer need to keep, and withdrawal of consent, and you may nominate a person to exercise your rights in the event of death or incapacity. Contact us using the details above. We may need to verify your identity before acting on a request.
Children
The Service is not intended for anyone under 18, and we do not knowingly collect children's personal data.
Cross-border processing
Some service providers may process data outside India. Where they do, we will ensure the transfer complies with Indian law, including any restrictions notified by the Government.
Grievances
For privacy concerns, contact our grievance officer: Noushad Nellanchery, info@smghorizon.com. See also grievance redressal. Once the relevant provisions are in force, you may also approach the Data Protection Board of India after exhausting our grievance process.
Changes
We will update this policy as the Service or the law changes and show the revision date at the top.