PRIVACY POLICY

BACKGROUND

The Indian Privacy law came into effect from April 11, 2011 on notification by India’s Ministry of Communications and Information Technology, who notified the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 under the Information Technology Act, 2000 with necessary provisions under the said rules.

APPLICABILITY

This privacy policy of Pentad securities private limited (herein referred as PSPL & Pentad interchangeably) shall also apply to all employee, stakeholders, our branches, business associates (including Authorised person & sub-broker) and subsidiaries located abroad, especially, in countries which do not or insufficiently apply the Privacy rules, to the extent local laws and regulations permit. When local applicable laws and regulations prohibit implementation of these requirements, the same shall be brought to our notice. In case there is a variance in standards policy prescribed in India and by the regulators of the host country, branches/overseas subsidiaries of intermediaries are required to adopt the more stringent requirements of the two.

CONTENT

At PSPL, we are committed to protecting your privacy (personal and financial information) in accordance with Indian privacy laws or the professional ethics permits. This Privacy Policy describes our current policies and practices in relation to the handling and use of personal information.

SALIENT FEATURES

  • Sensitive Personal Data/Information (SPD) – PSPL takes due care in dealing with information generally, personal information and “sensitive personal data or information” (“hereinafter, SPD”). SPD is defined to cover the following: (a) passwords, (b) financial information such as bank account or credit card or debit card or other payment instrument details; (c) physical, physiological and mental health condition; (d) sexual orientation; (e) medical records and history; and (f) biometric information. It may be noted that SPD deals only with information of individuals and not information of businesses.
  • Information Gathering and Management- The information is provided when you open the broking/trading and /or Demat account or register with us to receive certain services or products of PSPL, such as online /offline share trading etc.We provide any/all information that the regulatory body either ask for in form of mandatory & non-mandatory submission or as desired by us to manage the organisational risk.On some pages (physically or electronically) we provide a form for you to enter your details so we can contact you back or to process further for providing the services, where we ask for your name, email address, PAN, contact number and your location etc. in order to respond to your enquiry. We give you the option in order to improve our response to you. We also use your information to send you requested product information and promotional material and to enable us to manage your ongoing requirements and our relationship with you. We may occasionally notify you about new services and special offers, events or articles we think will be of interest to you. We may send you regular updates by email or by post on related matters. If you do not wish to receive it, email or write to us.We strive to maintain the reliability, accuracy, completeness and confidentiality of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements, We hold the information we collect from you in both electronic and hard copy format on our office premises. We put our best effort to ensure that your information is safe by implementing physical security on our premises and requiring passwords to access our electronic systems.

    We do not sell, trade, or rent your personal information to others; however under certain below mentioned circumstances, we share your information

    • On asked by any of the regulator including SEBI, RBI, FIU, GOI etc.
    • As a part of normal business to provide the service like demat & trading, wherein registration & providing information are compulsory as part of normal legal/regulatory purposes required by the Securities and Exchange Board of India and other regulatory and government entities, and
    • Wherein we invite selected third parties to participate in offers or to provide the services availed by you or may be availed in future.
    • Where in for business perspective, it is necessary or compulsory to disclose your personal information to our associated person, employees, agents and contractors, or to their subcontractors. However these parties would be required to use the information for such use exclusively.
    • With entities from time to time as PSPL feel deemed to share.

    We may need to provide your information to our related entities or intermediaries connected to us in addition to regulators. However, we do our best to ensure that they protect your information in the same way that we do but further don’t provide the guarantee for the same.

    Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate.

    Anonymous data – We use technology to collect anonymous information about the use of our website, for example when you browse our website our service provider logs your server address, the date and time of your visit, the pages and links accessed and the type of browser used. It does not identify you personally and we only use this information for statistical purposes and to improve the content and functionality of our website, to better understand our clients and markets and to improve our services.

    In order to collect this anonymous data we may use “cookies”. Cookies are small pieces of information which are sent to your browser and stored on your computer’s hard drive. Sometimes they identify users where the website requires information to be retained from one page to the next. This is purely to increase the functionality of the site. Cookies by themselves cannot be used to discover the identity of the user. Cookies do not damage your computer and you can set your browser to notify you when you receive a cookie so that you can decide if you want to accept it. Once you leave the site, the cookie is destroyed and no personal or other information about you is stored.

  • Consent for collection. PSPL cannot collect SPD unless it obtains the prior consent of the provider of the information. The consent has to be provided online click, by letter, fax or email or by default consent. PSPL must also, prior to collecting the information, give the option to the provider of the information to not provide such information. In such case, PSPL can cease providing services for which the information is sought.
  • Notification. PSPL does its best to ensure that the provider of the information is aware that the information is being collected, the purpose of use of the information, the recipients of the information and the name and address of the agency collecting the information.
  • Use and retention. PSPL can use personal information only for the purpose for which it was collected and it doesn’t retain the SPD for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law.
  • Right of access, correction and withdrawal. PSPL permits the provider of the information the right to review that information and should ensure that any information found to be inaccurate or deficient be corrected. The provider of the information also has the right to withdraw its consent to the collection and use of the information.
  • Transnational transfer. PSPL will only transfer the SPD or information to a party overseas if the overseas party ensures the same level of protection provided for under the Indian rules. Further, the information can be transferred only if it is necessary for the performance of a lawful contract between the PSPL and the information provider.

EXCEPTIONS

  • It is to be noted that section 69 of the Act, which is an exception to the general rule of maintenance of privacy and secrecy of the information, provides that where the Government/Regulator is satisfied that it is necessary in the interest of:
    • The sovereignty or integrity of India,
    • Defence of India,
    • Security of the State,
    • Friendly relations with foreign States or
    • Public order or
    • For preventing incitement to the commission of any cognizable offence relating to above or
    • For investigation of any offence,
    • Regulator may by order, direct us to intercept, monitor or decrypt or cause to be intercepted or monitored or decrypted any information generated, transmitted, received or stored in any computer resource

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