Privacy Policy - National Pension System (NPS) | HDFC Pension

Privacy Policy – National Pension System

1. Introduction

This Privacy Policy is applicable to all customers and potential customers of HDFC Pension Management Company (hereafter referred to as ‘HDFC Pension’ or ‘HPMC’) and users/visitors of or website and services made available under it by HDFC Pension.

Please read this Privacy Policy carefully. By accessing the website OR using the Life99 App OR using any of our Services, You represent/agree that You have read and understood the terms and conditions of usage, which includes this Privacy Policy and You agree to be bound by all its terms.

This Website is not intended for use by children and minors. Parents are requested to ensure that Personal Information is not provided by minors.

The Privacy Policy outlined herein is not intended to and do not create any contractual or financial or any other legal rights in favour of any User or viewer or any other party.


2. Definitions

The following definitions shall be applicable to this Privacy Policy;

  • “HDFC Pension” or “Us” or “We” or “HPMC”– refers to HDFC Pension Management Company Limited.
  • “Privacy Policy” – refers to this policy.
  • Personal Information” –means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person “Sensitive Personal Data or Information”-of a person means such personal information which consists of information relating to;— (i) password; (ii) financial information including but not limited to such as Bank account or credit card or debit card or other payment instrument details ; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) Biometric information; (vii) any detail relating to the above clauses as provided to body corporate for providing service; and (viii) any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise, provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information. It shall also include the Aadhaar number and/or the biometric information associated with an Aadhaar number as defined under the Aadhaar Act, 2016 and associated amendments under the act as per UIDAI (Unique Identification Authority of India).
  • “Services” – all Services made available by HDFC Pension.
  • “Third Party Service Provider(s)” – means the group companies / affiliates, third party vendors, agents, contractors, consultants or service providers.
  • “Website” – refers to and any subsequent pages under its sitemap.
  • “You” or “Your” or “User(s)” – refers to the person accessing the Website or utilizing the services of HDFC Pension in any capacity.


3. Information Collection

HDFC Pension collects information (including Personal/Sensitive Personal Information) in one or more ways as mentioned below:

  • Information You give Us:

Some of the Services made available to You require registration in order to create an account. The registration information typically asked may include information including but not limited to Your name, e-mail address, etc. which is voluntarily provided from Your end and help Us in personally identifying You. This information is necessary to initiate as well as continually use Your online account and products. If the information provided by You for such registration is wrong or has changed or misleading, You can update it quickly or delete it unless We have to keep that information for legitimate business or legal purposes. However, at the back end, audit trail keeping may require Us to retain copy / log of such informationfor as long as is legally permitted/required.


  • We may collect the following Personally Information from You (Please note that this is an indicative list):

Personal Information for purposes of this Privacy Policy includes information that identifies You and Your retirement savings, such as Your name, date of birth, bank account/ financial account details/ credentials, passwords, phone number, PAN, Aadhar, fax number or email address, gender, marital status, city of residence, basic salary, cost to company, contribution to retirement financial instruments such as EPF, PPF, superannuation, gratuity and leave encashment or any other information which is obligatory pursuant to regulatory requirements etc. Most features of the Website would require registration information, which may require You to provide Your details such as an email address or mobile number, a password and other information as may be required for registration. Any Kind of Personal Information collected would depend on nature of service being availed or proposed to being availed by You.

From time to time, the Website may also request other Personal Information to provide You with other benefits of the services or other value-added services. On all such occasions, You will have the opportunity to provide or to decline to provide that Personal Information. In case You do not provide the required information, You may not be able to avail the service or the product.


Information We get from Your use of our Services on the Website/App:

 Visiting and using Services offered under the Website by HDFC Pension may result in the Website receiving performance and usage information such as the date and time of Your visit, the kind of browser or computer You use, default language setting, Your unique Internet Protocol address, the number of links You click within the Website, the pages You viewed on the Website, and the web page from which You arrived to our Website. This information however will not be used to personally identify You.

In case of use of facilities/products/services through any APP, additional terms and conditions governing the manner of usage of APP including collection and disclosure of Personal Information shall be applicable and to be read along this Privacy Policy. HDFC Pension shall not be liable or responsible for any liability/damages arising from use of such third-party APP’s or any breach of data privacy which happens at their end.


  • Information we may get from our affiliates or third parties:

We may obtain information about You from other sources, including commercially available sources, such as social media, data aggregators and public databases. We may also collect information about You from Our affiliates or group companies.


  • Information We get through sending one or more cookies or anonymous identifiers to Your device:

Cookies are small electronic text files that contain information that a Website uses to store User preferences and settings. You are also being made aware that HDFC Pension cannot control the use of cookies or the resulting information by advertisers or third parties hosting data on respective HDFC Pension website. You have the option to reset Your browser to control cookies; however, some of the Services offered by the Website may not function properly if cookies are refused / reset / deleted.

  • In case You do not provide Your information or consent for usage of personal information or later on withdraw Your consent for usage of the personal information for the purpose it was collected or submit misleading and/or False information or fail to update the Your information , HDFC Pension reserves rights to discontinue/cancel the services for which, the said information was sought and any decision of HDFC Pension in this regard shall be binding on You and shall supersede the terms of the services.



4. Update Personal Information

HDFC Pension   encourages You to update Your Personal Information as and when there are any changes. You are also entitled to review the information provided and ensure that any information found to be inaccurate or deficient is corrected or amended as feasible. HDFC Pension shall not be responsible for the authenticity of the Personal Information or sensitive personal data or information supplied by You. All Personal Information so provided will be on an ‘as on’ basis. HDFC Pension shall not be responsible for any actions or policies of any Third Party Service Providers and Users are requested to check the applicable privacy policy and acquaint themselves with the terms and conditions of usage of such Third Party Service Providers while providing Personal Information. HDFC Pension shall be not liable for any variance in the features/benefits offered by such Third Party Service Providers and shall not in any case assume warranty on the efficiency or efficacy of such offers.


5. Use of Information

Any information that We collect from You may be used for a variety of purposes including but not limited to the following:

  • To provide You with pension related products that You may purchase from HDFC Pension
  • To address You enquiries or complaints and or any other customer services related activities
  • To provide Services to all Users of the Website/App
  • To personalize Your experience
  • To improve our Website/App, products and customer Service
  • To process transactions, where requested, under Your User ID and Password
  • To send periodic emails/SMS’s/mobile notifications/ WhatsApp messages
  • To administer a contest, promotion, survey or other site or business feature
  • To close a sale as well as for post sales information gathering
  • To communicate with You for any other post sales requirement
  • To conduct statistical analysis
  • To develop better products/solutions or improve services using artificial intelligence, machine learning, behavioural analysis and other technologies.
  • For sales and marketing activities
  • For Aadhaar authentication and sharing, storing, using Aadhaar data, as per the applicable laws
  • For detecting and protecting against error, fraud or identification of other criminal activity
  • For sharing with any regulatory, statutory or judicial authorities for compliance with any law or regulation in accordance with this Privacy Policy
  • And as otherwise informed to You at the point of collection

For any of these purposes, We may use Third Party Service Providers. We may also use them to help us in providing the features of the Website/App, such as sending email or messages on our behalf,   for such services, and notifying or contacting You regarding any problem with such services or hosting and operating a particular feature or functionality. However We will not be liable for any of the damages incurred by such Third Party Service Providers.

You recognize and understand that there is no compulsion on You to provide us with Your Personal Information and any and all Personal Information provided by You to Us is with Your full consent, own volition and desire to provide such Personal Information in order to procure the services.


6. Sharing of Information

  • HDFC Pension or its Website/App does not collect any personal information (except in relation to online purchase) unless voluntarily provided by You, and HDFC Pension confirms that it shall not rent or sell any of Your Personal Information. However, You would be required to provide Personal Information in the course of Your purchasing or initiating a transaction for purchase of pension products (if any), or for initiating any other Service request / transaction under any product purchased by You.
  • HDFC Pension will require Personal Information to be shared/exchanged and disclose for external processing with Third Party Service Providers or vendors:
    • To meet requirements of any applicable law, regulation, legal process, enforceable governmental request or customary practice directly or through our affiliates / banks / financial institutions / credit bureaus / agencies
  • To meet requirements of participation of any telecommunication or electronic clearing network
  • For statistical analysis and verification or risk management
  • To enforce applicable terms of Service, including investigation of potential violations
  • To detect, prevent or otherwise address fraud, security or technical issues
  • To protect against harm to the rights, property or safety of HDFC Pension, our Users or the public as required or permitted by law; and
  • To comply with PFRDA guidelines and/or as required under applicable laws. Your usage of the Website would also imply Your acceptance of the aforesaid terms.
  • HDFC Pension retains the right to share non-personally identifiable information with third parties for business purposes, to assess Website traffic, patterns and other such purposes. HDFC Pension also retains the right to share non-personally identifiable information to comply with applicable legal and regulatory processes, or to protect and defend the rights and interests of HDFC Pension and its affiliates and/or other Users or to enforce the terms and conditions which are binding on all Users of the Website.


7. Communication

HDFC Pension retains the right to communicate with You (via e-mail, postal Service / courier or mobile messaging Services, WhatsApp and telephone or social media extensions) when You have agreed to receive such communication or where operational or regulatory requirements require Us to do so. HDFC Pension further retains its right to communicate through Third Party Service Providers. By providing Your contact information You have consented with Your free will to be contacted by us on the said contact Information even if the said contact is registered under the National Customer Preference Register (“NCPR”) Registry.

You shall have the option to unsubscribe to receive such communications.


8. Third Party Offers

HDFC Pension may allow third parties to offer subscription and/or registration-based Services through the Websiteor link, App or other platforms (viz. WhatsApp, Twitter, Alexa, etc.). HDFC Pension shall not be responsible for any actions or policies of such third parties and users are requested to check the applicable privacy policy and acquaint themselves with the terms and conditions of usage of such service providers, when providing personally identifiable information. HDFC Pension shall be not liable for any variance in the features / benefits offered by such third parties and shall not in any case assume warranty on the efficiency or efficacy of such offers.

HDFC Pension shares certain Personal Information with third parties for activities including, but not limited to:

  • Marketing purposes
  • Document management/retention
  • Cloud storage
  • Logistical activities such as printing, Courier of documents, etc.
  • Cross-selling and up-selling of products of the HDFC Pension or group/parent companies.
  • Customer support provided by call centres
  • Improving services and products


9. Changes to Privacy Policy

The Website may amend or modify, this Privacy Policy including replacing this Privacy Policy with a new Policy, at any time at the sole discretion of HDFC Pension. Users are requested to periodically check the terms and conditions under this Privacy Policy from time to time. HDFC Pension shall not in any circumstance be held liable for such lapses on the part of the users.


10. Information Security

We take reasonable precautions to protect Your Personal Information or Sensitive Personal Data or Information from unauthorized access/alteration, disclosure or destruction. In particular:

  • We provide role-based access to employees/partners who need to login to our systems/ applications
  • We review our information collection, storage and processing practices, to guard against unauthorized access to systems
  • We permit access to personally identifiable information to our employees, contractors and agents who are subject to strict contractual confidentiality obligations for data processing purposes
  • We provide password based authentication access to Users who login to our Website/App. However, You are responsible for maintaining the confidentiality of Your login ID and password and You should not provide these credentials to any third party. We recommend that You change Your password periodically. We shall not be responsible if someone else accesses Your account through login ID and password they have obtained from You or through a violation by you of this Privacy Policy or the Website’s Terms
  • Communications between Your computer/mobile and our Website are encrypted using at least 128-bit secure socket layer technology (“SSL”). This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery. The Website also encrypts Your Website password so that Your password cannot be recovered, even by us


11. Storage of Information

HDFC Pension uses third party data centres and cloud services to securely store Your data and to minimize the possibility of data loss. The relevant security safeguards and contractual clauses as required by relevant Laws are adhered to while storing Your data.


12. Retention of Information

HDFC Pension shall not retain any Personal Information or Sensitive Personal Data or Information beyond the period necessary to satisfy the purpose for which it is processed (unless it is required by local regulations and applicable laws). In some circumstances, HDFC Pension may anonymize the data so that it can no longer be associated with the User, in which case HDFC Pension may use such data without further reference to the user. In case of deactivation / termination of the account / services or withdrawal of consent by You, the Personal Information provided may no longer be used for providing the services/facilities and the same may also get removed upon the expiry of the maximum tenure as may be prescribed under the provisions of the law as applicable or as per HDFC Pension privacy policy on data retention. Unless the Personal Information is purged permanently, the Personal Information may remain on the servers and we may use the Personal Information for data analytics purposes and procedures for improving the provisions of services/facilities by them in a non identifiable manner.


13. Warranty Disclaimer

Information, content and materials provided on this Website are on an “As Is” basis and HDFC Pension does not make any express or implied representation or warranty regarding the accuracy or completeness of the same.



14. Contact Information

HDFC Pension Management Company Limited,

13th Floor, Lodha Excelus, Apollo Mill Compound,
N.M. Joshi Road, Mahalaxmi, Mumbai – 400 011.
Email ID: [email protected]

Phone No. : 08916687777