PRIVACY POLICY

We at Nirmal Capital, endeavour to ensure the confidentiality, integrity, and security of your and your family’s personal information, at all times. We want you to understand how we protect your privacy when we collect and use your personal information personal information during business, as well as the measures we take to safeguard your personal information.

This Privacy Policy explains:

HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

Pre-registration — You cannot access any section or features of Nirmal Capital without registering or disclosing any personal information. As and when you download and install the app, remember that we capture anonymous visitor data such as pattern of your usage of app. We use this data together with similar data from other visitors to understand and control the usage of the app only in certain areas where our services are currently available.

Registration – To access the Nirmal Capital application, you will be asked to register for an registration account. This involves creating a Username and Password (collectively, “Login Credentials”)

Investment – To avail the functionality of our investment services and start investing, you will require to provide us with certain additional information such as:

• Contact Details such as name, father’s name, age, e-mail address etc.
• Demographic Data such as your mailing address, pin code etc.
• Bank account details with which you will be investing
• Any other documents required under KYC norms such as PAN card details, Aadhar Number etc.

(Collectively, your “Registration Information”).

We further need photographic evidence verifying your bank account such as image of the first page of the passbook or any cancelled cheque in order to verify that the bank account belongs to the Customer. Kindly provide us with the correct banking details as upon withdrawal any money received by the Customer gets deposited directly to your mentioned bank account. We may also ask for additional personal information from time to time to meet new regulatory requirements or to provide you with other benefits of our Services.

In case you wish to track investments made outside Nirmal Capital we will require your E-mail Id registered with the mutual fund folios. We use this Email Id to generate and deliver your mutual fund account statements that will be delivered to your inbox. Our systems automatically read the relevant email with the subject “CONSOLIDATED ACCOUNT STATEMENT – CAMS/KARVY Mail back Request” to process your investment information seamlessly and display it on the app for you to track. We assure you that emails with any other subject apart from the one mentioned above are not read/opened by us. In case, you do not wish to provide us with your E-mail id registered with the mutual funds, you will be required to manually upload your investment related information on our application to access our services and keep track of the investments made without using our platform.

Nirmal Capital will use information to better serve you and enhance your experience with the Services. Here are some examples of the ways we use your information:

• To administer your account;
• To send you investment related information.
• To provide you monthly investment statement.
• To conduct research and analysis.
• To respond to customer service inquiries.
• To send marketing materials, if opted.
• To improve our access to the App.
• To meet any regulatory requirements.
• To facilitate the processing of a data between you and a third party.

SHARING YOUR PERSONAL INFORMATION

Under no circumstance will we sell or rent your personal information to anyone, for any reason, at any time. Access to your Login Credentials, Registration Information, and any other personal information you provide is restricted and used in accordance with specific internal procedures in order to operate, develop or improve our services.

We share your investment related information to Bombay Stock Exchange in order to verify your credentials to meet our regulatory obligations.

We may also use third party vendors, professionals such as advisors or service providers to help us provide services to you, such as maintaining the track record of your investment or couriering documents to you on our behalf or operating the payment gateway functionality of the website. Such third parties are required to maintain the confidentiality of the information we provide to them under contract and under law.

If your advisor terminates his or her relationship with us and moves to another investment advisory firm (“New Firm”), we or your advisor may disclose your personal information to the New Firm, unless you instruct us not to.

We reserve the right to disclose your personal information in the scope and in situations as required by the law and when we believe in good faith that such disclosure is necessary to protect our rights, to report suspected illegal activity, comply with judicial proceedings, court orders or decisions, or legal process served on our website.

We may also use Your information, and/ or permit selected third parties including service providers, on the Website, with Your prior consent, to use Your information or provide You with such information which may be of interest to You and We and/ or they may contact You about the same. If You wish to be so contacted by the third parties, any information You provide to such third parties may be read, collected, and used by them. Notwithstanding the abovementioned, You may choose to stop receiving such information from the third parties by writing to us at “support@nirmalcapital.com”

THIRD PARTY WEBSITES

Our website may, from time to time, contain links to and from the websites of Our partner networks, affiliates and other third parties. This Privacy Policy does not cover the collection of information by cookies or other methods by third parties. We do not control how such third parties collect information or by what means as such third parties may use their own cookies to collect information about you. Please remember that after we disclose any personal information to third parties, we can no longer control the use of such personal information. Accordingly, Nirmal Capital will not be liable for the acts or omissions of any third party. Please check these policies and the terms of the websites before You submit any information to these websites.

INFORMATION STORAGE AND SECURITY

We have implemented a wide range of measures in order to ensure the security and confidentiality of your data. These include physical, electronic, and administrative safeguards such as firewalls, data encryption, SSL and other up-to-date technologies.

No security measures, however, are 100% complete. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or private communications will not be collected and used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for the unauthorized use of your information or for any lost, stolen, compromised passwords, or for any activity on your Account via unauthorized password activity.

We cannot guarantee the security of your data while it is being transmitted over the Internet and through servers that are out of our control. We do our best to protect your personal information but we cannot ensure or warrant the security of any information you transmit to our website or Services. Therefore, if you make any data transmissions over the Internet, you are doing it at your own risk. Once we receive the data transmission, we make our best efforts to ensure its security and privacy on our systems.

HOW YOU CAN ACCESS AND UPDATE YOUR PERSONAL INFORMATION

Your personal information is yours. To access or update your information, please login and make changes as required. Some of these changes may require you to provide documentary evidence. As an added security measure, we may require additional proof of identity prior to such disclosure. Remember to keep your Login Credentials safe and secret to prevent unauthorized access to your Nirmal Capital account. If you think that the security of your account has been compromised, change your password, and contact us immediately for further assistance.

OUR LEGAL OBLIGATION TO YOU

We are bound by the (Indian) Information Technology Act, 2000, and comply with all its provisions. Under Regulation 4 of the Information Technology (Reasonable Security and Procedures and Sensitive Personal Data or Information) Rules, 2011, Nirmal Capital Pvt Ltd. is obliged to provide every registered user of Nirmal Capital with a readable copy of the information that it keeps about you. If you would like a copy, do get in touch with us at the address provided below.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is published on the app in compliance with Regulation 4 of the (Indian) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.

We update this Privacy Policy periodically. We will not reduce your rights under this Privacy Policy without your explicit consent. We will notify you of any changes to this Privacy Policy. The date of last revision appears at the top and all changes take effect immediately upon posting. For the purposes of this policy, “personal information” means any information that can be used to identify you personally.

TERMINATION

If your relationship with us ends with us, we will continue to treat and protect your personal information in accordance with this Privacy Policy. That means that we may continue to share your personal information with our partners and affiliates as described above or permitted by law. However, if you notify us of your election not to have us share your personal information with others, we will honour that request.

APPLICABLE LAW AND JURISDICTION

This Privacy Policy shall be governed by, construed and entered in accordance with the laws of the Republic of India, without regard to choose of law or conflict of law provisions thereof. All disputes with respect to this Privacy Policy shall be brought and heard in the courts situated at Chennai, India.