Equinova Investment Managers Private Limited (the “Equinova“), or any third party service provider, functionary, or agent appointed by Equinova acting on its behalf (together, the “Equinova“, “we“, “us“, “our“) are committed to protecting your personal data and are required, by Data Protection Legislation (as defined below), to provide individuals with certain information about how we use your personal information and sensitive personal information.

This privacy notice and policy (“Privacy Policy“) explains what information we collect from you, or you provide to us, how we use it and with whom we share that information. The Privacy Policy also sets out your rights and who you can contact for more information.

In this Privacy Policy:

• your information is sometimes called “personal data“;
• your information is called “sensitive personal data” if it contains passwords, financial information such as details of bank account/other financial instruments, and biometric information;
• we may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as “processing” such personal data; and
• the term “Data Protection Legislation” means applicable laws including Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (Privacy Rules).

For the purposes of Data Protection Legislation the data controller is EQUINOVA.

1 What information we collect about you

We may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Legislation and as set out in this Privacy Policy.

The personal data we, collect and process may include:

• information obtained from identification documentation (including your name, contact details, place etc.);
• financial information, tax status, account details and evidence of ownership of financial assets;
• personal identifiers such as your pan number, Aadhaar number, IP address, or our internal electronic identifiers;
• information related to your usage of our PMS Portfolio Portal through our website, such as Internet traffic statistics, network state, IP address, date and time of access, and details of visited pages;
• other information you provide in the course of your dealings with us or which we require to provide you with products and services.

The sensitive personal data we collect and process may include, bank and demat account details.

Please note that we collect the aforementioned sensitive personal data and Aadhaar information on the basis of your consent, which you provide us when you sign the terms of our agreement with us, for the collection, storage, use, processing, sharing and/ or transfer of such information, as applicable, in the manner provided under this Privacy Policy.

2 How we collect your information 

The information we collect (or may collect in future) comes from:

• application forms or other materials you or your authorised representative submits to us during the course of your relationship with the Equinova;
• you or your authorised representative’s interactions with us, transactions and use of our products and services (including the use of any our websites or mobile applications);
• your or your authorised representative’s business dealings us, including via email, telephone or as stated in contracts with you;
• cookies that uniquely identify your browser, or device, and store certain types of personal data each time you visit our website or application;
• depending on the products or services you or your authorised representative requires, third parties (including for credit and money laundering checks, among other things); and
• recording and monitoring tools that we use for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, etc.).

3 How we use your information

Our primary purpose in collecting your personal information is to facilitate and accept your investment in Equinova products or services, the management and administration of your investment in Equinova products or services and any related administration on an on-going basis.

Additionally, we use your information for the following specific purposes:

• to process transactions and to improve the quality of the service that we provide to you;
• to disclose information to other third parties such as service providers of Equinova, auditors, regulatory authorities and technology providers for the purposes outlined in this Privacy Policy
• for prudential and risk management purposes;
• to provide you with any products and services that you request from us; and
• if it is necessary to use it for any other reason and that reason is compatible with the primary purpose.

4 Legal grounds for using your personal information

Data Protection Legislation permits us to process your personal data in the way that we do because the processing is:

• necessary for the purposes of the legitimate interests that we pursue, which are to run and administer the products or services, to discharge our statutory/legal obligations, to store and disclose information where necessary and to evaluate, develop and improve our services; or necessary for the performance of a contract with you; or
• necessary in order to comply with a statutory/legal obligation to which we are subject.

5 Providing your information to third parties 

The following categories of recipients may receive your personal data and process it for the purposes outlined in this Privacy Policy:

• any regulatory, supervisory or governmental authorities to the extent we are required by law to do so, and in certain other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud).

Equinova is committed to ensuring the confidentiality of your information. We only share your personal data with third parties when necessary for the purposes outlined above or as required by law. Equinova does not undertake marketing activities for third parties, nor does it provide information to third parties for their own marketing purposes.

In relation to transferring or disclosing your sensitive personal data to third parties, Equinova will ensure that such third parties adopt adequate security measures and safeguards as per applicable laws.

6 Automated processing 

We do not carry out automated decision-making or profiling.

7 How long we keep your information 

We will only keep the information we collect about you for as long as required for the purposes set out in this Privacy Policy or as long as required for us to comply with any statutory/legal obligations to which we are subject.

8 How we protect your information 

We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect your personal data from unauthorised access in accordance with applicable law.

9 Changes to Privacy Policy

This Privacy Policy may be amended from time to time without notice, in which case the date of this Privacy Policy will be revised.

Additionally, if our Privacy Policy changes in any way, we will place an updated version on our website and where required under applicable law take your consent for such updates.

10 Other

This Privacy Policy is for your information and should not be used as the basis for any decision to purchase or redeem investments in EQUINOVA managed products or services. The views and information expressed in this policy do not constitute and may not be relied upon as constituting any form of investment advice or inducement to invest, and prospective investors must obtain appropriate independent professional advice before making investment decisions.