Welcome to Echoes.

Privacy Policy

Thinking Wealth Pvt Ltd, incorporated in the Republic of Mauritius, granted a Global Business License under Section 72 of the Financial Services Act 2007 and an Investment Adviser (Unrestricted) License under Section 30 of Securities Act 2005. (“we”, “us” and “our”) is committed to protecting and respecting your privacy.

This privacy notice will inform you as to how we look after your personal data when you visit our Mobile Application (regardless of where you visit it from) and when you interact with us directly. It will also informyou about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

The purpose of this privacy notice:

This privacy notice aims to give you information on how we collect and process your personal data through your use of this Mobile Application, including any data you may provide through this Mobile Application.

Our Mobile Application is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with the End User License Agreement so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Thinking Wealth Pvt ltd is the controller for your personal data.

If you have any questions about this privacy notice, please contact the data privacy representative using the details set out below.

Contact details

Email address: support@thinkingwealth.ai

Changes to the privacy notice and your duty to inform us of changes

This version was last updated in January 2024

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party Applications

This Mobile Application maybe integrated to third-party plug-ins and applications to develop and deliver our features. Usage of these features may allow third parties to collect or share data about you. We do not control these third-party Mobile Applications and are not responsible for their privacy statements.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  1. Identity Data includes first name, last name, username or similar identifier and profile picture.
  2. Contact Data includes email address and telephone numbers.
  3. Technical Data includes internet protocol (IP) address, your login data, time zone setting and location, operating system and platform and other technology on the devices you use to access our Mobile Application.
  4. Usage Data includes information about how you use our Mobile Application, such as usage patterns.
  5. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Mobile Application feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact data by filling in forms. This includes personal data you provide when you and/or your Company:

  1. apply for our services;
  2. create an account with us;
  3. subscribe to our service or publications;
  4. participate in discussion boards or other social media functions on our Mobile Application;
  5. request marketing or communications to be sent to you;
  6. enter a survey; or
  7. give us some feedback.

Automated technologies or interactions. As you interact with our Mobile Application, we may automatically collect Technical Data about your equipment and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Mobile Applications employing our cookies.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the services rendered by the mobile application, more specifically to

  1. Personalize your experience within our application
  2. Monitor and moderate the community
  3. Respond to inquiries and provide support
  4. Improve and develop our services
  5. Comply with legal or regulatory obligations.

Promotional offers from us

We may use your Identity, Contact, Technical, and Usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing and communication).

You will receive marketing communications from us if you have requested information from us, attended an online event with us or if you have provided us with your details.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside our Company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time on support@thinkingwealth.ai

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your information with:

  1. Third-party service providers, strictly for the purpose of supporting our services
  2. Law enforcement or governmental authorities, if required by law

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. YOUR RIGHTS UNDER GDPR

If you are located in the European Economic Area (EEA), you have certain rights under the General Data Protection Regulation (GDPR), including:

  1. Right to Access: You can request a copy of the personal data we hold about you.
  2. Right to Rectification: You may correct or update your personal data.
  3. Right to Erasure: You may request the deletion of your personal data, subject to certain conditions.
  4. Right to Object: You may object to our processing of your personal data.
  5. Right to Data Portability: You may request a copy of your personal data in a structured, commonly used format.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

International Data Transfer

We do not transfer your personal data outside the EEA

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
  4. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DELETE YOUR INFORMATION OR ACCOUNT

To delete your information, you can

Find and delete specific information. We offer tools you can use to delete certain information. For example, you can use Delete buttons to delete content you’ve posted to your account. When you delete content, it’s no longer visible to other users.

Permanently delete your account

If you delete your account we delete your information, including the things you’ve posted, such as your images and status updates, unless we need to keep it as described in ‘Retention of User Data and Content’ Once your account is permanently deleted you won’t be able to reactivate it, and you won’t be able to retrieve information, including content you’ve posted. However, we delay deletion a few days after it's requested. A deletion request is cancelled if you log back into your echoes account during this time.

How long does it take to delete your information?

If you request that we delete your account or content, it may take up to 90 days to delete your information after we begin the account deletion process or receive a content deletion request. After the information is deleted, it may take us up to another 90 days to securely remove it from backups and disaster recovery.

If you delete your account:

Retention of User Data and Content

Should you have any questions or concerns regarding data retention or deletion, please refer to our full Privacy Policy or contact our Data Protection Officer at dataprotection@thinkingwealth.ai .

echoes is committed to maintaining a safe and secure financial discussion environment. As a part of this commitment, we retain user data and content for a specific period, even after a user initiates the account deletion process. This retention is in line with our responsibilities as a regulated financial entity and is crucial for the protection of our community. Copies of your information may remain after the 90 days in backup storage that we use to securely recover in the event of a disaster, software error, or other data loss event. We may also keep your information for things like legal issues, terms violations, or harm prevention efforts.

User-generated content, including posts, comments, and interactions, may be retained for 90 days after an account deletion request or may be longer. This retention allows us to:

We may also preserve information from accounts that have been disabled and content that has been removed for violations of our terms and policies. If we disable an account for violating our terms or policies, we preserve information about that user to prevent them from opening a new account. We also might preserve some of your account information as part of our review of suspicious activity. This includes any suspicious activity associated with our financial products, like suspected money laundering or terrorist funding.

Please be assured that we take data privacy and security seriously. Access to retained user data and content is strictly controlled and used solely for the purposes mentioned above. We follow stringent security protocols to protect this information from unauthorised access.

Your trust and security are of utmost importance to us, and we are committed to maintaining a transparent and safe financial discussion platform for all our users.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We implement appropriate technical and organizational measures to protect your personal data. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. USER RESPONSIBILITY FOR CONTENT ACCURACY AND RELEVANCE

  1. Accuracy: Users are responsible for the accuracy of the data they submit and the content they post within the community. We do not verify or endorse the accuracy, relevance, or completeness of any user-generated content.
  2. Relevance: Users must ensure that their contributions are relevant to the topics and discussions within the community.
  3. Harmful Content: Users are prohibited from posting content that is illegal, offensive, abusive, or otherwise harmful. We reserve the right to remove or moderate such content at our discretion and in accordance with our community moderation principles.
  4. Disclaimer: We shall not be liable for any errors, inaccuracies, or harm resulting from user-generated content. Users are encouraged to exercise caution and independently verify any information obtained from the community.

10. USE OF DATA IN AI MODELS

  1. Purpose: We may utilize user-generated data, including content and interactions within the community, to train artificial intelligence (AI) models. The purpose of these models is to enhance and improve our services, personalize user experiences, and develop new features.
  2. Anonymization: When used for AI modelling, personal data will be anonymized and aggregated to ensure that individual identities are not identifiable.
  3. Consent: By using our application, you consent to the use of your data, including content posted within the community, for the purposes described above. If you do not wish your data to be used in this manner, you may opt-out by contacting us at support@thinkingwealth.ai.
  4. Compliance with Laws: Our use of data for AI modelling complies with all applicable laws and regulations, including GDPR. We take appropriate measures to ensure the privacy and security of your data in this context.