PRIVACY POLICY

This Privacy Policy sets forth the reasonable security practices and procedures adopted by Capitalworx Advisers LLP (“Capitalworx”) for its website www.capitalworx.in and shall apply to the use and disclosure and sharing of sensitive personal data or information (“Personal Information”) provided by the registered users of the Website/Web Application /web application www.capitalworx.in (“Website/Web Application” or “Web Application”), which is owned, maintained and operated by Capitalworx. This policy is equally applicable to the visitors/users on the Website/Web Application.

We value the trust you have placed with us. To provide you with a convenient and safe online experience, we have implemented measures to protect the confidentiality, integrity, and security of your Personal Information, during storage and transmission through the World Wide Web. This Privacy Policy explains how we protect personal Information provided by you through the Website/Web Application /Web Application and how we store and use that information, to deliver the services on the Website/Web Application.

By entering this Website/Web Application and providing personal information when subscribing and sending enquiries to us, you expressly agree to this privacy policy. By entering this Website/Web Application, you shall be treated as having given your consent to process your personal information as set out in the Privacy Policy.

This Privacy Policy is in conformity with the Industry Standards and Practice, however is subject to change at any time. It is advised that you review this Privacy Policy periodically. This Privacy Policy is also incorporated into and subject to the Terms of Use of the Website/Web Application.

Personal Information

Personal information means any information that relates to a natural person, which directly or indirectly is capable of identifying that person.

The personal information collected from you and covered within this Private Policy may include your full name, address, telephone/mobile number, email address, PAN number, Bank account number and other information as defined in Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive data or information) Rules, 2011, as may be required by us from time to time in order to provide services to you. However, you have the right to modify or update your personal Information/details with us.

Collection of Personal Information

Most features of the Website/Web Application would require registration, which may require you to provide your details such as an email address, a password, PAN number and other information.

In case, you avail the services of dealing in online transactions (including mutual funds) through Capitalworx Customer ID on the Website/Web Application, in such case you will be required to provide Personal Information like your Name, Address, PAN, Bank Account Number and other information required as per applicable regulations [“KYC information”] at the time of registration/activation of such facility. The collection of this KYC Information is obligatory pursuant to regulatory requirements in order to activate and enable the online transactions. Such KYC information shall be used/shared/maintained/accessed/stored with/by third party technology service provider/AMCs/RTAs/authorized service providers in order to enable/facilitate/complete/process online transactions and report/statement generation.

From time to time, the Website/Web Application may also request other personal information to provide you with additional benefits of the services as selected by you. On all such occasions, you will have the option to provide or decline to provide that personal information.

In order to benefit from the full functionality of the services, you would need to provide your Account Credentials/Information to allow the Website/Web Application, to provide an account aggregator services to access your account data from the financial institutions/banks where your accounts are maintained, to enable you to use/see consolidated view of various accounts. All such Account Credentials/Information and data collected from such accounts are stored by us on highly secured servers. The section “Your data is secure” shall describe the various security mechanism followed for securing your data.

You agree and understand that your personal information shall be collected, processed, stored and used by us, and passed to other data processors including our agents, for the services identified under this Privacy Policy.

Use of Personal Information

The Website/Web Application uses and discloses your Personal Information only as follows:

• To fulfill / complete your requests for products and services offered, or subscribed or availed by you on the Website/Web Application.

• To deliver to you any administrative notices, money alerts and communications relevant to your use of the services.

• To any Governmental Authority including but not limited to the Reserve Bank of India or the Securities Exchange Board of India.

• To Third Party Service Providers (including payment gateways) that provide services to Capitalworx and are bound by these same privacy restrictions.

• To any organization for verifying for identifying the investor for complying with Anti Money Laundering Act.

• To comply with orders of the Court, any applicable law or any statutory or legal requirements or process.

• To analyze Website/Web Application usage, improve features, tailor the Website/Web Application to your interest’s and improve the services offered.

• For market research, troubleshooting problems, detecting and protecting against error, fraud, hacking or other criminal activity.

For any of these purposes, we may use group companies / affiliates, third party vendors, agents, contractors, consultants or service providers (individually a ‘Third Party Service Provider’ and collectively, the “Third Party Service Providers”). Such Third Party Service Providers are bound by privacy restrictions which are similar to the restrictions mentioned in this Privacy Policy.

Sharing and disclosure of Personal Information

We will not disclose your Personal Information with any affiliated or unaffiliated third parties, except as stated under:-

• To provide you the product and services.

• To enforce the terms and conditions of the products or services.

• For transaction processing and report generation.

• To protect the interests of Capitworx, its affiliates, directors, officers, employees, representatives and authorized agents.

Capitalworx may aggregate Personal Information, and disclose or use such data only in a non-personally identifiable manner (anonymously) for purposes of research, advertising, comparison to organizations approved by Capitalworx.

If you choose the option of deactivating your account with us from the Website/Web Application, your data will be permanently deactivated on our servers and no one including us shall have any access to your account. The access shall only be provided to comply with orders of the Court, any applicable law or any statutory or legal requirements.

The Website/Web Application will also promptly disconnect any connection it had established to your linked accounts and deactivate all account Credentials/Information.

Notwithstanding anything above, portions of your data, consisting aggregate data derived from your Account Credentials/Information, may remain on servers indefinitely. Your data may also remain on our backup server. These backups are required to ensure our continued ability to provide the services to you in the event of malfunction or damage to primary production servers.

Promotional Communication from the Website/Web Application

The Website/Web Application will provide you with periodic summaries of your Account Information and send email / SMS alerts. The Website/Web Application also allows you to subscribe to email newsletters, research information and from time to time may transmit emails / SMS promoting the Website/Web Application or third-party products or services. You have the ability to opt-out of receiving our promotional emails / SMS and to terminate your newsletter subscriptions by following the instructions on the Website/Web Application. Opting out in this manner will not end transmission of service-related emails / SMS – such transactional alerts.

Third Party Services and Website/Web Applications

You should be aware that Capitalworx shall permit third parties to offer subscription and/or registration-based services through the Website/Web Application. Capitalworx shall not be responsible for any actions or policies of such third parties, and you should check the applicable privacy policy of such third parties while providing personally identifiable information. Further, Capitalworx will not be responsible for any services/ benefits announced, if any, by the third parties permitting to offer subscription and registration based services on its Website/Web Application.

Personal information will not be sent/transferred to these third parties by Capitalworx unless reasonable steps have been taken to maintain the required level of data protection.

Blog on financial investment and other Forums on the Website/Web Application

While using a bulletin board, blog or chat room on the Website/Web Application, you should be aware that any information you submit there can be read, collected or used by other users/visitors and could be used to send you unsolicited messages. The Website/Web Application and Capitalworx are not responsible for any personal information you choose to submit in these forums. These forums shall be hosted by the Website/Web Application or by our Third Party Service Providers on behalf of Capitalworx.

Use of Cookies and Online session information

The Website/Web Application will automatically receive and collect certain anonymous information in standard usage logs through our web server, including computer-identification information obtained from “cookies” sent to your browser from a web server or other means. “Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your web browser on your computer’s hard drive.

The Website/Web Application uses cookies for a number of purposes. For instance, to enable us to simplify the logging on process for registered users, to help ensure the security and authenticity of registered users, etc. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to eliminate cookies, the full functionality of the services may be impaired for you.

Your Data is Secure

When you register for the services, the Website/Web Application requires a Login ID and a password from you for your privacy and security. For further security, OTP (One Time Password) will be generated and will be sent on your registered mobile number for enabling your online transactions. You are responsible for maintaining the confidentiality of your Login ID, password and OTP. You should not provide these credentials/information to any third party. It is recommended that to protect yourself and your online information you should change your password periodically.

Your password must conform to standards and, as a security feature the Website/Web Application will automatically reject weak passwords. It is recommended that you should pick a strong password for online security .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/Web Application’s Terms of Use.

While accessing your linked accounts online, the Website/Web Application uses a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session, and to protect Website/Web Application accounts and systems from unauthorized access. From the time you submit your Login ID and password, these communications between your computer and the Website/Web Application 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/Web Application also encrypts your Website/Web Application password so that your password cannot be recovered, even by us.

For enhanced security, all Account Credentials/Information of your Bank/Financial Institution provided by you, for your use / consolidated view are encrypted and stored by us in a highly secured data center.

Breach of Internal Security

Despite our best efforts as stated above, if un-authorized persons breach our security control measures beyond our control resulting in the site being hacked, Capitalworx shall not be held responsible for the same.

Feedback

If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, you can contact at care@capitalworx.in