Microcurves Retail broking Privacy policy

1 YOUR PRIVACY

1.1 Emint app , websites - www.emint.in and www.microcurvetrading.com are owned by Microcurves Trading Private Limited, a company incorporated under the Companies Act, 2013 having CIN: U93000GJ2014PTC124048, and having its registered office at Unit #208 and 209, 2^nd floor, Xchange Plaza, Dalal Street Commercial Cooperative Society Ltd, Block #53, Road 5e, Gift City, Gandhinagar- 382355, Gujarat. Microcurves is a Trading Member of National Stock Exchange of India Limited (“NSE”), and is registered with Securities and Exchange Board of India (“SEBI”) with Registration No. INZ000298936. Microcurves is also registered as a depository participant (CDSL) with SEBI with Registration no.: IN-DP-744-2023.(“Microcurves”, “us”, “we” or “our”) is committed to protecting your privacy and will take the relevant measures to safeguard your personal information in accordance with the Information Technology Act, 2000 (the “IT Act”) and The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the “SPDI Rules”) and other applicable laws, rules and regulations etc. (collectively referred to as the “Data Protection Laws”). This Privacy Policy (the “Policy”) sets out the type of information collected by us and how we use such information and safeguards/measures which we undertake to protect the personal information you share with us.

1.2 Your personal data will be held by us in accordance with the Data Protection Laws.

2 YOUR PERSONAL DATA

            Categories of personal data

2.1 We, or a service provider engaged by us, may collect and process personal data from you. The personal data collected from you may include (but may not be limited to) personal data that falls into the following categories of data:

2.1.1 name;

2.1.2 personal, business, financial and contact information (including home address, email address, phone number, emergency contact, gender, marital status);

2.1.3 date of birth;

2.1.4 signature;

2.1.5 any Government issued ID or passport number or other identification numbers as appropriate (e.g., Aadhaar, voter ID/driving license/permanent account number );

2.1.6 nationality and place of birth;

2.1.7 other personal data as may be required from time to time for business planning and management; and

2.1.8 certain “sensitive personal data” regarding biometric information, passwords (including password selected by the applicant and applicant’s response to selected security question), financial information such as bank account, credit card, debit card or other prepayment instrument details, health condition (mental, physiological or physical), and any details relating to the above provided to us during the course of our business relationship, for the purposes described above or as required by law.

            How we will collect your personal data

2.2 We may collect and process your personal data in the ways set out below:

2.2.1 We may collect and process information that you provide by filling in forms for us (whether electronic or not). This includes information (such as your email address) provided at the time of responding to any request for information from us.

2.2.2 We may collect and process information that you provide us as part of or in connection with our business relationship or contract.

2.2.3 If you contact us, participate in any survey conducted by us or provide any feedback, we may keep a record of that correspondence.

2.2.4 We may collect and process details of your visits to our website and/or mobile app including, but not limited to, traffic data, location data, weblogs, your browser type, operating system, internet protocol address, internet service provider and other communication data, and the resources that you access.

2.2.5 We may collect and process your personal data from third parties, other service providers/our business partners or from publicly-available sources. This inter-alia may include sourcing information from registered stock brokers, social media websites etc.

2.2.6 We may collect personal information using cookies stored on your browser or your system (which may provide us additional information about your usage), unless you have opted to disable/block cookies.

2.2.7 If you use our mobile application(s), we also may collect the following information if you choose to provide us with access or permission:

(i) Mobile Device Access - We may request access or permission to certain features from your mobile device, including your mobile device’s camera, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

(ii) Push Notifications - We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

2.3 By providing us your personal information through our website, mobile application or any other means, you are giving us your express voluntary consent to collect, use, process and/or share your personal information in accordance with this Policy. If anytime in future, you do not agree with the terms of this Policy or any amendments made to this Policy, you are advised to immediately inform us and discontinue use of our website and mobile application.

3 PURPOSE OF PROCESSING AND USES MADE OF THE INFORMATION

3.1 We collect and use information held about you in the following ways:

3.1.1 To ensure that content from our website/mobile application is presented in the most effective manner for you and other users.

3.1.2 To provide you with any information/product(s)/marketing material that you request from us or which we feel may interest you, including information on networking and stakeholder events organised by Microcurves. Microcurves and/or any of our group companies (which means our subsidiaries, our ultimate holding company and its subsidiaries), or any of its related and associate companies and affiliates as well as any company in which we, or any of our group companies, have an investment (together, the “Microcurves Group”), as permitted under applicable law or where you have consented to be contacted for such purposes.

3.1.3 To carry out our obligations arising from any contracts entered into between you and us. This may inter-alia also include (a) sending communication/updates/newsletters etc. from time to time; (b) taking steps to protect product(s)/service(s)/user data etc; (c) seeking professional advice from time to time.

3.1.4 To evaluate your suitability to avail the relevant services from Microcurves or any member of the Microcurves Group .

3.1.5 To analyse activities on our website/mobile application and convert the same in structured form for further processing to improve our product(s)/service(s) or use the same for the benefit of Microcurves Group (we may also use services of third party entities to analyse such data).

3.1.6 To comply with our obligations and any requests received regarding background and security screening (including know your client and anti-money laundering screening) and/or to undertake/facilitate compliance with any judicial/legal/regulatory requirements/requests.

3.1.7 To prepare and execute legal documents.

3.1.8 To process payments made by you towards fees and other charges payable, and comply with our accounting, audit and tax obligations.

3.1.9 For administrative, business and record keeping purposes.

3.1.10 For contact purposes.

3.1.11 To comply with our obligations regarding security and access within the Microcurves Group.

3.1.12 To investigate complaints and to identify and prevent suspected suspicious/fraudulent/unlawful transactions or any attempts made to undertake such suspicious/fraudulent/unlawful transactions.

3.1.13 To compile and create anonymised/aggregated data pool which can be used for any purpose as Microcurves deems fit (including using it for further analysing/processing data, publishing on any platform/forum or for marketing/research etc.)

3.2 Your information is necessary to us. If you do not provide all of the personal data that we request from you, we may not be able to fulfil all of the functions set out in paragraph 3.1 above.

3.3 Your information may also be shared by us with third parties for undertaking any of the activities as mentioned above and by providing us your personal information through our website, mobile application or any other means, you are giving us your express voluntary consent to collect, use, process and share your personal information with third parties. If anytime in future, you do not agree with the terms of this Policy or any amendments made to this Policy, you are advised to immediately inform us and discontinue use of our website and mobile application.

3.4 Any activity on third party websites (even if such website is accessed after being redirected from Microcurves website/mobile application) would be subject to the privacy policy published by respective third party website and Microcurves shall not be liable for any data breach/misuse of data by such third party website.

3.5 In cases where Microcurves is facilitating certain functionalities/features on the basis of agreements with a third party or external service provider then use of any such functionality/feature would also be subject to the privacy policy published by such third party or external service provider. For instance, Microcurves has a tie-up with TradingView ( https://www.tradingview.com ) to facilitate usage of charts on Microcurves website/mobile application. So any usage of functionality/feature offered by TradingView on Microcurves would additionally be subject to the TradingView’s own privacy policy which is a separate policy (unrelated to this Policy of Microcurves). This is for reference only, and Microcurves has and may from time to time have tie-ups with other third parties and external service providers.

4 WHERE WE STORE PERSONAL DATA AND DISCLOSURE OF YOUR DATA

4.1 Currently all your data is stored locally in India. Where we transfer your sensitive personal data within or outside India, we will ensure that your sensitive personal data is transferred to only a person or a body corporate that ensures the same level of data protection that is adhered to by Microcurves under the Data Protection Laws and we will take reasonable steps to ensure that your data is treated securely and in accordance with the Data Protection Laws and this Policy.

4.2 Unless you specify otherwise, we may disclose your personal information to:

4.2.1 any member of the Microcurves Group (whether in India or offshore);

4.2.2 any third parties (including those outside of India) in the following circumstances:

(i) in the event that Microcurves sells or buys any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

(ii) if Microcurves or substantially all of its assets are acquired by a third party, in which case personal data held by it will be one of the transferred assets;

(iii) to avail service(s) from agents, service providers and third parties who provide such service relating to the purposes for which the personal data is collected and processed including data processing services or which provide network or administrative services, whether or not such agents, service providers and third parties are based in India;

(iv) if any such person is under a duty of confidentiality and has undertaken to keep such data confidential; or

(v) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Microcurves or any members of the Microcurves Group, our business partners or others.

4.3 We do not disclose your personal data to other unaffiliated third parties other than those indicated in this Policy without your consent.  However, we may disclose your personal data if required by law or in good faith, if such action is necessary to comply with any law enforcement agency requirements, court orders or legal processes.

            Retention

4.4 We may retain any personal data which we may obtain for such a period as we deem fit and/or as required by applicable law. If we no longer need to use your personal data for the purposes set out in paragraph 3 above and/or we are not legally required to retain your personal data, we will take reasonable steps to destroy your personal data or render it anonymous.

5 SECURITY MEASURES

5.1 We will take all reasonable precautions necessary to protect your personal data from: misuse, interference and loss, and unauthorised access, processing, modification or disclosure.

5.2 We may use third party data storage providers to store personal information electronically. We take reasonable steps to ensure this information is held as securely as information stored on our own equipment.

5.3 Please note that, unfortunately, there is always risk involved in sending information through any channel over the internet. Any information you send to us over the internet is entirely at your own risk. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet. Subject to applicable laws/instructions from governmental/regulatory authorities, we will endeavour to inform you  in case we notice any breach in our security control which may have resulted in unauthorized access to your information as a result of any deficiency in our security. However, neither Microcurves nor any member of the Microcurves Group shall be liable to you/anyone else for any loss (whether direct or indirect) as a result of such breach.

5.4 Where we transfer your sensitive personal data within or outside India, we will ensure that your sensitive personal data is transferred to only a person or body corporate that ensures the same level of data protection that is adhered to by Microcurves under the Data Protection Laws and we will take reasonable steps to ensure that your data is treated securely and in accordance with the Data Protection Laws and this Policy .

6 Use of Aadhaar related Information

6.1 During your online account opening process, you do not input any Aadhaar details on the Micorcurves platform. You would be issuing your Digital Aadhaar to Digilocker, from where Microcurves (Microcurves is registered as a Requester on the Digilocker platform) would receive information, based on your consent to allow Digilocker to share such information with Microcurves, limited to: (1) The last four digits of your Aadhaar / VID (Virtual ID created on the UIDAI website), (2) Full Name, (3) Date of Birth, (4) Gender, (5) Address, and (6) Your Photo.

6.2 Digilocker is a part of the National eGovernance Division under the Ministry of Electronics & Information Technology (MeitY), Government of India. The Digital Aadhaar issued within DigiLocker is the same as the eAadhaar issued by UIDAI (https://eaadhaar.uidai.gov.in). DigiLocker has partnered with UIDAI to make it available automatically to its users when they link their DigiLocker account with Aadhaar. This act of issuing an eAadhaar within Digilocker and subsequently Digilocker sharing the information limited to the above points, leads to behaving as a physical KYC. Microcurves only receives information limited to the above points for the purposes of completing KYC of clients online.

6.3 During your online account opening process, you would also be sharing your Aadhaar with Digiotech Solutions Pvt. Ltd. for the purpose of digitally signing the Microcurves account opening form. Digiotech Solutions Pvt. Ltd. does not share your Aadhaar with Microcurves. After the account opening form has been digitally signed by you, a copy of the digitally signed form would be emailed to you and to Microcurves for reference/audit purposes. Digiotech Solutions Pvt. Ltd. is a licensed e-Sign ASP (Application Services Provider) with CDAC, compliant with the guidelines laid down by the Controller of Certifying Authorities (CCA), India and UIDAI, to enable you to eSign the account opening forms online.

7 ACCESS, CORRECTIONS AND COMPLAINTS

7.1 You may review your personal information by contacting our Grievance Officer Pankaj Kumar Singh at grievances@microcurvetrading.com. Further, you may also correct or amend any personal information by contacting our Grievance Officer if such information is inaccurate or deficient.

7.2 If you have a concern about how we have handled your personal data, please let us know so we can fix the problem. You can contact us at grievances@microcurvetrading.com.

7.3 To lodge a complaint, please send details to our Grievance Officer in writing.    We treat all privacy complaints seriously and any complaint will be assessed by our Grievance Officer with the aim of resolving any issue in a timely and efficient manner.  We request that you cooperate with us during this process and provide us with any relevant information that we may need to investigate the complaint appropriately.

8 PROCESSING IN LINE WITH YOUR RIGHTS

8.1 You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) the purpose for which we intend to use your data or if we intend to disclose your information to any third party. You can exercise your right to prevent such processing by checking certain boxes on certain forms we use to collect your data. . You can also exercise the right at any time by contacting us at support@microcurvetrading.com.

8.2 Our forms and website may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

9 MONITORING AND REVIEW OF POLICY

Microcurves may review and change this Policy from time to time to reflect changes in the law, our business practices, processes or structure and will make the latest draft of the Policy available on the website/mobile application. You should keep yourself updated about the changes made by Microcurves in this Policy from time to time.