Privacy Commitment

Marwadi Shares and Finance Limited and its subsidiary and/or affiliate companies as defined under relevant laws including Marwadi Commodity Broker Private Limited, Marwadi Stock Broking Limited, Marwadi Bullions Private Limited and Marwadi International Securities(IFSC)Limited (hereinafter referred to as“MSFL/we/our”), take the privacy of its customers, or any other person visiting or using any office, branch, website, portal, application or other platform provided by MSFL or communicating with us over the telephone, WhatsApp, Telegram, face-to-face or any other method or availing the products and services physically or vide the online application forms and questionnaires (hereinafter referred to as “User / you / your” ) very seriously and are committed to protecting your personal data. This Privacy Commitment sets out the way in which we collect, use, disclose, transfer, and store your personal information/data.

You are advised to carefully read the Privacy Commitment before using this or any other platform, application or channel or communicating with us or sharing information/data. MSFL will not be liable /responsible for any breach of privacy owing to User’s negligence.

Please note that our application and other digital platforms may contain links to third-party applications/digital platforms which are provided for your convenience. We are only responsible for the privacy practices and security of our own digital platforms. We recommend that you check the privacy and security policies and procedures of each and every other application/ digital platform that you visit.

1. INFORMATION COLLECTED FROM YOU

A. We understand clearly that you and your Personal Information is one of our most valuable assets. We store and process your Information including any Personally Identifiable Information ‘PII’ collected, if any, on computers that may be protected by physical as well as reasonable technological security measures and procedures in accordance with regulatory authorities.
B. Personal data is data that can be used to identify or contact a single person such as:

• i. Your full name, address, e-mail address, telephone number, date of birth and bank or payment card details and any proof of your identity and/or address that we may request including Your Aadhaar details and any alternative virtual identity issued as an alternative to the actual Aadhaar number generated by UIDAI;
•  Details of any transactions you carry out through our Website using your MSFL account and of the fulfilment of your requests;
• Details of any bank account (including but not limited to, account holder, account name, account number, sort code, online banking PIN, Transaction Authentication Number "TAN" and password, available balance and transaction history of your bank account), ITR, TAX certificates or any other income documents as necessary by us;
• Biometric information such as photographs;
• Details of any credit, debit or other card used by you for transactions;
• Your participation in any promotion sponsored by us;
•  Correspondence that you send us;
• Calls that we make to you or you make to us;
• Surveys that you complete through the Website or based on our request;
• Information is collected through cookies. Please see Paragraph I (Cookies) of this Privacy Policy for more details;
• Your IP address, location details, SMS, log-in times, operating system and browser type;
• Your contact list information to detect fraud and assess risks; and
• Details of your visits to our Website include but are not limited to, Traffic Data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access whilst visiting our Website.

C. In order to fulfil our legal obligations to prevent fraud and money laundering, we will obtain information about you from third-party agencies ("Third Party Information"), including your financial history, court judgments and bankruptcies, from credit reference and fraud prevention agencies when you open an MSFL account and at any time when we feel it is necessary to prevent fraud and minimize our financial risks. Please refer to the paragraph on Anti-Money Laundering Policy of this Privacy Policy for further details. Personal Information and Third Party Information are collectively referred to as "Information".

D. MSFL will collect your Personal Information including your Aadhaar number/virtual identity directly from the Aadhaar number holder for conducting authentication with UIDAI at the time of providing services. Virtual ID in lieu of an Aadhaar number at the time of authentication may be used.

E. Provision of Aadhaar details is mandatory as identity information for OTP-based e-KYC, as per the Master Direction - Know Your Customer (KYC) Direction, 2016.

F. All personal data that we collect about you will be recorded, used, and protected by us in accordance with applicable data protection legislation and this Privacy Commitment. We may supplement the information that you provide with other information that we obtain from our dealings with you or that we receive from other organizations, for example, our sponsors and partners.

G. We may collect such personal data through telephonic conversations with any employees or representatives of MSFL or any of its customer service agents and/or any other mode of communication or submitted by you vide documents, images or in any other form and whether in the physical or digital/online mode. You agree that any such communication whether written or oral may be recorded to comply with MSFL’s internal processes or any applicable law.

H. You represent to us that you are above the age of 18 and are in a contracting capacity to access our platform and share your personal data with us.

I. Please note, if you don’t choose to provide us with the requested personal data, we will be unable to offer you our products or services.
 

2. USAGE OF YOUR INFORMATION

In broad terms, we use your personal data for the following purposes:

• To administer and provide products and services you request or have expressed an interest in;
• To communicate with you in the event that any products or services you have requested are unavailable;
• For fraud screening and prevention purposes and to protect MSFL’s legal rights and comply with MSFL’s legal obligations;
• For record-keeping purposes, to comply with laws and regulations, and to comply with other legal processes and law enforcement requirements;
• To carry out market research so that we can improve the products and services we offer;
• To track your activity on our digital platforms;
• To create an individual profile for you so that we can understand and respect your preferences;
• To personalize and improve your experience on our digital platforms and allow you to utilize digital platforms’ features by granting MSFL access to information from your device;
• To personalize and/ tailor any communications that we may send you;
• For profiling purposes to enable us to personalize and/or tailor any marketing communications that you may consent to receive from us;
• To inform you about important details like MSFL’s digital platforms, change in terms, conditions and policies and /or other administrative information important to meet your interests;
• To address your requests and queries and manage your relationship with MSFL;
• To access your eligibility for our products or services and provide you with such products or services which you may have shown interest in or requested for;
• To perform activities such as data analysis, audits, and usage trends to determine the effectiveness of MSFL’s campaigns and as input into improving products and services;
• For security and business continuity and risk management;
• For system or product development and planning, audit and administrative purposes;
• To meet the legitimate interests to be pursued by MSFL or by a third party.

A. When you sign up with us for an online account, register to receive marketing communications from us, filling one of our forms (whether online or offline), contact us or otherwise expressly provide us with your personal data, we may collect and store any personal data that you provide to us and may use it to personalize and improve your experience on our digital platforms, provide products and services you request from us, and carry out profiling and market research.

B. We may also infer your country of location from the IP address you have used to access our digital platforms and we may analyze which marketing activity led to your taking specification on our digital platforms (e.g. downloading the app).

3. OFFERS AND OPPORTUNITIES FROM US AND OUR PARTNERS

We want you to be the first to know about new products and services, and occasional offers from our partners. We may share these offers with you only with your prior consent. You can unsubscribe from receiving these offers by emailing us. Please note, if you don’t choose to receive this information, we will be unable to keep you informed of new services, products, events or special offers that may interest you.

4. WHY DO WE PROCESS YOUR INFORMATION?

A. We may process your personal data for legitimate interests, including providing you with services and for service improvement purposes.

B. It may be deemed necessary to process personal data for the following purposes of legitimate interests by us such as:

• To deliver services with respect to requests raised by you.
• To ensure continued relationships with our customers, partners or suppliers 
• To prevent misuse or fraudulent activities on our platforms.
• To uphold the performance of contracts with us. 
• Protecting our interests.
• To maintain compliance with legal obligations.

C. MSFL takes special consideration to ensure that the legitimate processing of data does not override the fundamental rights and freedoms of the User.

5. WHOM DO WE SHARE YOUR PERSONAL DATA WITH?

A. Under certain conditions MSFL may share your information with third parties including but not limited to its group companies, vendors, service providers, data processors, banks, financial institutions.

B. Credit bureaus, telecommunication companies, statutory bodies etc. for customer verification, personalization of products and services, credit rating, data enrichment, marketing or promotion of the products or services of MSFL or of any other service provider. MSFL may use the personal data to improve its services to you and to keep you updated about its new products or other information that may be of interest to you.

C. MSFL may share information in the course of normal business operations, such as providing services you have subscribed for, and any activity related to these services such as collection of fees. It may become necessary for MSFL to disclose your personal data to its agents and contractors in the course of normal business operations for the above referred purpose. However, these parties would be required to use the information obtained from MSFL for such purposes exclusively. MSFL will endeavor to take all reasonable steps to ensure that the confidentiality of your information is maintained by third parties to whom it discloses such information. MSFL may be required to disclose your personal data to the statutory authorities in connection with any legal process that may be initiated by such authorities in accordance with applicable laws.

D. MSFL may occasionally invite selected third parties to participate in offers we feel would be attractive to customers of MSFL. MSFL may also share your information to provide you with superior services and a range of offers. MSFL may use this information to advise you of products, services and other marketing materials, which we think, may be of interest to you. MSFL may also invite visitors to this site to participate in market research and surveys and other similar activities. MSFL reserve the right to communicate your personal information to any third party that makes a legally compliant request for disclosure.

6. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

A. You are responsible for providing MSFL with accurate and complete personal data. Please notify us of any changes to your personal data. MSFL shall take reasonable steps to ensure that your personal data is kept accurate, complete, and current.

B. MSFL shall not retain such Information longer than permissible. Such information however may be retained for a longer period where we need the information for legal, regulatory, accounting or other legitimate purposes which may include but not be limited to filing/ addressing complaints, responding to any queries raised by any of our regulators/ customers/ governmental bodies, any legal claims etc. To determine the appropriate retention period for personal data, MSFL considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which it processes your personal data and whether it can achieve those purposes through other means, and the applicable legal requirements. In some circumstances MSFL may anonymize your personal data so that it can no longer be associated with you and use such information.

C. MSFL only collects data from Users in accordance with the consents obtained from such Users and after informing them about the consequences of refusing to provide personal data or withdrawing consent for the identified purposes and maintains a record of such consents. This Privacy Commitment also covers the terms of the consents granted by you to MSFL for the information submitted by you. All information provided by you is purely voluntary and optional and you may choose not to provide the information. You may also withdraw your consent to collect/ provide/share/process the information by communicating to the email id given below in writing. However, in any of the above cases (i) you may not be able to access some of the features or pages of the digital platform/ applications (ii) you may not be able to avail some or all of our products or services or if you have already availed, such products or services may be withdrawn, curtailed or cancelled as per the terms thereof. In some cases, it is essential for the information to be collected/retained/stored/processed/shared either regulatory, or as a matter of policy or for any of the purposes above and you are requested not to avail the products or services if you do not wish to provide the information or provide consent to collect/share/process the same since it may not be possible to delete/purge/return such information if you choose to withdraw consent. For any queries in this regard, you may contact the email ids mentioned later in this document.

D. MSFL ensures that an appropriate data privacy commitment is provided to the Users at the time or before collecting their personal data including Sensitive Personal Data either by the terms of this Privacy Commitment or otherwise.

7. HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

A. MSFL has put in place procedures to deal with any suspected data security breach and will comply with the legal requirements in this regard. MSFL is strongly committed to protecting the privacy of its Users and has taken all necessary and reasonable measures to protect the confidentiality of the customer information and its transmission through the world wide web and it shall not be held liable for disclosure of the confidential information when in accordance with its privacy policy or in terms of the agreements, if any, with the customers. MSFL uses procedural and technical safeguards to secure your information from unauthorized access and use, alteration and destruction. In addition, access to your personal data is limited to only those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on MSFL’s instructions, and they are subject to a duty of confidentiality.

B. In addition, like most platforms, MSFL uses small bits of data called “Cookies” stored on users’ computers to simulate a continuous connection. “Cookies” let MSFL store information about your preferences and passwords and allow you to move to different pages of our secure site without having to re-enter your password information. Any information collected is stored in secure databases protected via a variety of access controls and is treated as confidential information by MSFL. Therefore, you should be careful with the usage of the username and password by maintaining confidentiality and ensuring that you do not knowingly or accidentally share, provide and facilitate unauthorized use of it.

C. MSFL will protect your personal data against unauthorized use, dissemination or publication in the same manner in which MSFL would protect its confidential information of like nature.

D. Phishing

• Phishing is the name given to attempts to steal personal details and financial account details from a website user. "Phishers" use fake or "spoof" emails to lead users to counterfeit websites where the user is tricked into entering their personal details, such as credit card numbers, user names and passwords.
• If you receive such an e-mail or are asked for your password by anyone claiming to work for us please forward the e-mail or report the incident by e-mail to Inquiry@marwadionline.in.

8. WHAT ARE YOUR PRIVACY RIGHTS AND HOW CAN YOU EXERCISE THEM?

A. We provide you with reasonable access to view and review your personal data and request correction and deletion where appropriate. In order to protect your privacy, we will take reasonable steps to verify your identity before granting access to your personal data.

B. If you have any questions, comments or concerns about how we handle your personal data, then you may contact us as per the details mentioned in the following paragraph.

C. You have the right to tell us if you:

• would like to confirm whether the company processes data about you;
• would like to access your data;
• would like to correct or update your personal data;
• would like to port your data or would like a copy of the personal data which we hold about you; 
• would like to delete your personal data from our records; and 
• would like to withdraw the consent provided earlier.

D. You also have the right to file a complaint to the authorities.

E.To exercise any of the above-listed rights you may contact the respective Privacy/Grievance Officers as per the aforementioned details. To assist us in dealing with your request, please provide your full name, address, date of birth, email address and some document for identification.

9. CHANGES TO OUR PRIVACY COMMITMENT

We may change our Privacy Commitment from time to time and post the updated version of the same. We encourage you to visit frequently to stay informed about how we use your personal data.

10. PROHIBITED ACTIONS

While visiting or using our application or digital platform, you agree not to, by any means (including hacking, cracking or defacing any portion of the website/applications/portals/platforms) indulge in illegal or unauthorized activities including the following:

• Restrict or inhibit any authorized user from using the application or digital platform
• Use the application or digital platform for unlawful purposes
• Harvest or collect information about the application or digital platform’s users without their express consent
• "Frame" or "mirror" any part of the application or digital platform without our prior authorization
• Engage in spamming or flooding
• Transmit any software or other materials that contain any virus, time bomb, or other harmful or disruptive component
• Remove any copyright, trademark or other proprietary rights notices contained in the application or digital platform
• Use any device, application or process to retrieve, index, "data mine" or in any way reproduce or circumvent the navigational structure or presentation of the application or digital platform
• Permit or help anyone without access to the application or digital platform to use the application or digital platform through your username and password or otherwise.

11. Links to Our Website and to Other Websites

A. Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own terms of use and privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. Please also note that the products and services offered on these websites may be limited to persons located or residing in only that particular jurisdiction. In addition, the content on these linked websites may not be intended for persons located or residing in jurisdictions that restrict the distribution of such content.

B. Our Website also includes social media features, such as the Facebook Like button and widgets, such as the "Share this" button or interactive mini-programs that run on our site. These features may collect your IP address, and which page you are visiting on our Website, and may set a Cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing them.

C. You must always obtain the prior written approval of MSFL before creating a hyperlink in any form from a third-party website to any webpage on the MSFL Website. MSFL may or may not give such approval at its absolute discretion. In normal circumstances, we may only approve a hyperlink which displays plainly our name or website address. Any use or display of our logos, trade names and trademarks as a hyperlink will not be approved unless in very exceptional circumstances and may be subject to a fee as MSFL may determine at its absolute discretion. MSFL is not responsible for the setup of any hyperlink from a third-party website to any MSFL website. Any links so set up shall not constitute any form of co-operation or partnership or collaboration with, or endorsement by, MSFL of such third-party website. Any link to our website shall always be an active and direct link to our website and shall be made directly to the home or front page of our website only and no "framing" or "deep-linking" of any webpage of our Website or content is allowed. 

12. Cookies

A. "Cookies" are small computer files that are transferred to your computer's hard drive that contain information such as user ID, user preferences, lists of pages visited and activities conducted while browsing the Website. At your option, expense and responsibility, you may block cookies or delete cookies from your hard drive. However, by disabling cookies, you may not have access to the entire set of features of the Website.

B. Generally, we use Cookies to customize your experience on our Website and to store your password so you do not have to re-enter it each time you visit the Website.

C. In addition, our business partners may use Cookies to provide us with anonymous data and information regarding the use of our Website.

D. We do not link the information stored in these Cookies directly to any of your Information you submit while on the Website.

E. In order to comply with legislation, we have reviewed the use of Cookies on our Website and set out the information below. This is to ensure that you are aware of these cookies and are able to give your consent for the placing of some or all of these cookies on your device when you use our Website. In summary, we use the following types of cookies:

a)Strictly Necessary Cookies
These are cookies which are essential for our Website to operate such as those which identify you so you can log into your MSFL account. They allow you to move around our Website and use the services you have requested. These cookies will be activated when you enter our Website and as you use our Website.
b)Compliance Cookies
These include Cookies which are necessary to assist in meeting our regulatory compliance obligations, such as anti-money laundering and anti-fraud obligations, and prevent your MSFL account from being hijacked. These cookies will be activated when you enter our Website and as you use our Website.
c)Performance Cookies
These are Cookies that help us to improve how our Website works and to deliver a better service to you. For example, they will assess which pages you visit most often or if you get an error message. They also allow us to see if you have used the Website of one of our group or affiliated companies. All information collected by these Cookies is aggregated and therefore anonymous.
d)Functionality Cookies
These cookies allow us to deliver a more personalized service to you and allow our Website to remember choices you have made such as the language you prefer or the region you are in. They may also be used to provide services you have requested such as being able to comment on one of our blogs.
e) Third-Party Cookies
When you visit a page on our Website with content embedded from third parties, for example, YouTube or Twitter, Cookies may be downloaded onto your device. We do not set or control these Cookies. If you are concerned about the types of Cookies that may be downloaded you check the third-party websites for more information about these Cookies.

We may use other Cookies from time to time in accordance with this Privacy Policy. By using our Website and other online services, you acknowledge that we may use some or all of the Cookies set out in this Privacy Policy and you agree that we can place performance and functionality Cookies on your device when you use our Website. If you do not agree to this you should cease using our Website and online services or adjust your browser settings.

F.Blocking Cookies
Should you want to continue using our services but restrict our use of Cookies, you can block Cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all Cookies (including Strictly Necessary and/or Compliance Cookies, as described above) you may not be able to access all or parts of our Website. Our Website may issue some of the Cookies described above as soon as you visit our Website unless you have adjusted your browser setting so that it will refuse Cookies.
 

13. HANDLING PRIVACY CONCERNS

If you have any questions about this Privacy Commitment or if you believe that your personal data is not handled in accordance with the applicable law or this document, then you may contact us as at Inquiry@marwadionline.in:

Details of our Nodal Grievance Redressal Officers are as under:

Registered Office Address of Marwadi Shares and Finance Limited –

X-change Plaza, Office No. 1201 to 1205, 12th Floor, Building No.-53E, Zone-5, Road 5E, Gift City, Gandhinagar-382355 Gujarat

Corporate Office Address of Marwadi Shares and Finance Limited –

Marwadi Financial Plaza, Nana Mava Main Road, Off 150 Feet Ring Road, Rajkot-360001, Gujarat 

14. Governing Law and Jurisdiction

This Privacy Commitment shall be governed by the laws of India and the Courts of Rajkot (India) shall have the exclusive jurisdiction to try any dispute arising thereof.