Privacy Policy

Preamble

Secure Mutual Solutions (hereinafter referred to as the “FIRM”/ “we” or “us”), is committed to safeguard the privacy and security of personal information of all users, investors, service providers, and stakeholders (collectively, “Users”) whose data may be collected or processed by the FIRM in the course of its operations.

Introduction

The FIRM is committed to protect your Personal Data. This Privacy Policy sets out the way in which we collect, use, disclose, transfer and store your Personal Data.

This Privacy Policy sets out the types of personal information (“Personal Data”) we may collect from you through our website, mobile application, and any other platform owned and/or operated by us (collectively referred to as the “Platform”), and the manner in which such data is used, stored, processed, and disclosed to third parties, including service providers, regulators, and intermediaries in compliance with SEBI regulations and the Digital Personal Data Protection Act, 2023 (“DPDP Act”).

This Privacy Policy also identifies the rights and options available to you with respect to your Personal Data and the manner in which you may reach out to us should you have any concerns or queries regarding this Privacy Policy.

We are committed to safeguarding your Personal Data through Reasonable Security Practices and Procedures in accordance with Applicable Laws. Should you choose to provide and thereafter not to continue providing us with the consent for the requested Personal Data, we will be unable to offer you, our Services.

You are advised to carefully read the Privacy Policy before using this or any other platform, application or channels for communicating with us or sharing information or Data (including any Personal Data) with us or our Representatives, or prior to using the Services. We shall not be liable / responsible for any breach of privacy owing to the User’s negligence.

Please note that the Platform 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 the Platform. We recommend that you check the privacy and security policies and procedures of each and every other application / digital platform that you visit.

All capitalized terms not defined in this document shall have the meanings ascribed to them in the Terms and Conditions of the Platform, which are available on the Platform.

1. Definitions

• (a) Affiliate(s): Shall mean with respect to the SECURE MUTUAL SOLUTIONS, any person directly or indirectly controlling, controlled by, or under direct or indirect common control with the SECURE MUTUAL SOLUTIONS including its proprietor and associate companies.
• (b) Applicable Laws: Means all provisions of laws, statutes, ordinances, rules, regulations, permits, certificates, judgments, decisions, decrees or orders of any governmental authority applicable to a Person, including the Digital Personal Data Protection Act, 2023, SEBI (Mutual Funds) Regulations, 1996, and the IT Act, 2000.
• (c) Consent: Shall mean the voluntary agreement to the processing of personal data for the specified purposes, either explicitly or deemed, in accordance with the Applicable Laws.
• (d) Data Principal: Shall mean the individual to whom the Personal Data relates, who is the User in the context of this Policy.
• (e) Data: Includes any personal, transactional, or financial information pertaining to an investor, client, or User that is collected, processed, stored, or transferred by the FIRM or its authorized service providers in accordance with the Applicable Law.
• (f) Data Fiduciary: Shall mean the FIRM, which determines the purpose and means of processing Personal Data.
• (g) Data Processor: Shall mean any entity that processes Personal Data on behalf of the FIRM.
• (h) Personal Data: Means any data about an individual who is identifiable by or in relation to such data.
• (i) Platform: Means the website, mobile application, and any other platform owned and/or operated by the FIRM.
• (j) Regulated Entities or REs: Entities that are registered with and regulated by the SEBI under applicable laws, including but not limited to Asset Management Companies (AMCs), mutual funds, custodians, registrars and transfer agents (RTAs), and KYC Registration Agencies (KRAs).
• (k) Representatives: Means the personnel employed or otherwise engaged by the FIRM or the group entities for the purpose of their respective businesses.
• (l) Services: Shall mean the investment-related services as provided for in the Terms and Conditions of the Platform, including but not limited to the onboarding of investors, facilitation of mutual fund transactions such as subscriptions, redemptions, and switches, portfolio reporting, folio servicing, and investor communications, as offered by the FIRM.
• (m) Third Party: Means any person other than the Data Principal and the Data Fiduciary.

2. What Personal Data Do We Collect?

We collect, transmit, and store Personal Data about you after obtaining your consent, to provide you with, or in connection with, our Services.

Such Personal Data includes:

• (a) Identity and profile-related information: Name, gender, title, photos, educational qualifications, location and employment details.
• (b) Contact information: Email addresses, phone numbers, and residential address.
• (c) KYC information: Government-issued officially valid documents such as PAN card, voter ID, GST details, Aadhaar card, etc., and any other document prescribed under the Applicable Laws from time to time, for the purpose of on-boarding / KYC requirements.
• (d) Transaction information: Details of transactions that occur through the Platform or are related to the Services, such as services you've requested or confirmed through the Platform.
• (e) Financial data: Your income information, payment details, bank account information, salaries, bank statements, investments, and related information through which services are provided to the investors.
• (f) Marketing and communications data: Your preferences regarding marketing messages from us and third parties, as well as your communication preferences.
• (g) Device data: IP addresses, browser types, time zone settings, operating systems, and device information. We may access your camera, microphone, or location (GPS data) solely for the purpose of onboarding or KYC checks, after obtaining your explicit consent.
• (h) Usage data: Information about how you use our Platform, including device information to provide security and to improve our services.

3. How and When Do You Consent to Usage and Sharing of Your Data?

(a) We only collect Data from Users in accordance with the explicit 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.

(b) You may withdraw or modify your consent to collect / provide / share / process the information (including your Personal Data) by communicating to the email ID given below in writing. However, in such instance, you may not be able to avail some or all of our Services.

(c) In some cases, information must be collected / retained / stored / processed / shared either regulatorily (e.g., KYC/AML compliance) or for any of the purposes above, and you are requested not to avail the Services if you do not wish to provide such information or provide consent to collect / share / process the same.

(d) The FIRM ensures that express consent for seeking, collecting, storing, utilizing and sharing their Personal Data is obtained at the time of or before collecting their Personal Data including any sensitive Personal Data.

(e) The Personal Data collected from you is stored at our backend servers and cloud servers situated in India.

4. What Do We Use Your Data For?

We use your Personal Data for the following purposes:

• Creating your account with us and onboarding you as a user.
• Establishing and verifying your identity for KYC, including for our Affiliates and the Regulated Entities.
• Administering and providing Services you request or have expressed an interest in.
• For fraud / Anti Money Laundering (AML) / name screening and prevention purposes and to comply with the FIRM'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 perform data analysis, audits, and usage trends to determine the effectiveness of the FIRM's campaigns and input into improving Services.
• To assess your eligibility for mutual fund investments and provide you with such Services.
• To address your requests, feedback, and queries and manage your relationship with the FIRM.
• To provide you with offers (including for financial products and/or services), personalized services and recommendations.

5. Whom Do We Share Your Personal Data With?

(a) The FIRM may share your information (including the Personal Data) with third parties including but not limited to:

• Asset Management Companies (AMCs) and Registrars and Transfer Agents (RTAs): As necessary for transaction processing and fulfilment, as this is the operational necessity of the service.
• Central KYC Registry (CKYCR): For KYC compliance and record-keeping.
• Statutory and Regulatory Authorities: SEBI registered intermediaries, any Indian or foreign statutory, regulatory, judicial, quasi-judicial authorities/agencies, including but not limited to Financial Intelligence Unit-India (FIU-IND).
• Service Providers: Call centres, fund accountants, custodians, banks, financial institutions, payment aggregators/gateways, technology providers, and third-party service providers appointed by the FIRM for specific outsourced functions like investor servicing and data analytics.
• Affiliates: The FIRM's Affiliates, for customer verification, personalization of Services, marketing or promotion of the Services of the FIRM.

(b) We will only share data necessary to facilitate the service, comply with legal obligations, or for the purposes explicitly stated above.

6. Governing Law and Jurisdiction

This Privacy Policy shall be governed by the laws of India and the courts of Puducherry (India) shall have the exclusive jurisdiction to try any dispute arising thereof.

7. Handling Privacy Concerns

If you have any questions about this Privacy Policy or believe that your Personal Data is not handled in accordance with the Applicable Laws or this document, you may contact us via email: secure.mutual.solutions@gmail.com

MUTUAL FUND INVESTMENTS ARE SUBJECT TO MARKET RISKS, READ ALL SCHEME RELATED DOCUMENTS CAREFULLY.