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Policy on Privacy & Security of Information

 

1.      Introduction

 

Welcome to the website www.barodamf.com (the “Website”). The content of the Website is the property of Baroda Asset Management Company Limited having its registered office at Raheja Titanium, Western Express Highway, Goregaon (East), Mumbai-400063 (Hereinafter referred as “AMC” or “Company” or “We” or “Us”). The Company is in the business of Mutual Fund (“Services”)

 

 This Privacy Policy is published in compliance of the Information Technology Act, 2000; and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.

 

2.      Preview: Management of Sensitive data and Personal Information

 

This Privacy Policy discloses and explains how we collect, use, share and protect Personal Information or Financial Information about You.  Information collected by Us vide the physical (offline) and online/electronic mode may be converted and stored in an electronic form at our sole discretion.

 

This Privacy Policy shall be read with and subject to the disclaimer notified on the Website. However, this Policy shall not apply to you in case you access and provide data to any other/ third party links available on the Website. AMC shall always follow all such rules prescribed under the Information Technology Act, 2000, and rules & procedural guidelines set by the Securities Exchange Board of India (“SEBI”) and/or other appropriate authorities under the law for the time being in force.

 

3.      Privacy Notice

 

This Privacy Policy is available on the AMC’s website. You are expected to read and familiarize yourself with this Policy. By visiting our website and using the Services as provided by Us (either through the Website, vide our various Internet and other applications or through the physical means) including but not limited to subscribing to our products, offering, sending of inquiries etc, you expressly agree to this Privacy Policy.

If you do not agree to this Privacy Policy, do not use the Website, and do not give us any of your information.

4.      Personal Information

In this Policy, Personal Information” means any information that directly or indirectly in combination with other information that We have or are likely to obtain, will help Us to identify You. Examples of personal information includes, full name, e-mail, addresses, telephone numbers, photographs, all employment-related and compensation-related information, and government-issued identification numbers.

Sensitive personal data or information of a person means such personal information which consists of information relating to passwords, financial information such as Bank account, credit card, debit card or other payment instrument details etc. received by Us or made available to Us.

Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information. AMC will not be responsible for any abuse of publicly available information.

5.      Collection of Personal Data

 

The AMC shall collect the data either directly or through third party service providers. While collecting the information directly / indirectly, the AMC shall ensure that the information provider has knowledge of:

(a)    The fact that the information is being collected

(b)    The purpose for which information is collected

(c)    The intended recipient of the information

(d)    The name and other relevant particulars of the third party collecting the information, if applicable.

 

6.      Use of Personal Data/ Information

We use and process, information for a range of purposes, which may include the following:

a.      To fulfil the Service requests. 

b.      To deliver notices or alert relevant to use of Services.

c.      To provide and administer Services.

d.      To facilitate transactions.

e.      To check the identity and suitability of information provider for certain products and Services.

f.       To ensure the security and operation of our Information Technology environment.

g.      To use it for marketing and advertising measures (e.g., newsletters via e-mail, online advertising).

h.      To detect, prevent and investigate fraud.

i.        To display content based upon your interest

j.        Facilitate and improve the usage of Services. 

k.      To comply with Applicable Laws, rules, and regulations.

l.        To comply with the legal process to respond to requests from public, regulatory or government authorities.

m.    We may share your information, including your personal information and usage Information with our parent, subsidiaries, and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Website or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.

n.      To perform internal business processes such as data analysis, audits, developing and improving new products and services.

o.      To share data with third party service provider/registrar and share transfer agent/ vendors/ facilitating agencies etc for fulfilment of transaction services. 

 

7.      Sharing of Personal Information with Third Parties:

 

To the extent required or permitted under law, we may share the Personal Information with the following parties for fulfilment of our commercial, contractual, legal, and other obligations:

 

a)     Registrar and transfer agent (s), call centres, Banks, custodians, depositories and/ or authorized external third parties, stock exchanges, brokers, clearing corporations who are involved in transaction processing, dispatches, etc., of investors’ investment with Us and/or who are vendors/ service providers/ distributors to whom commission is paid.

b)     Distributors or sub-brokers or intermediaries through whom applications are received and whose ARN number is stamped on the application form/ transaction slips.

c)      Any other organization for verifying the identity of investors for complying with anti-money laundering requirements.

d)     Any governmental authority including but not limited to the Reserve Bank of India and/ or the Securities and Exchange Board of India.

e)     In response to the request received from appropriate authorities to fulfil their audit, regulatory, compliance, investigative requirements.

f)       In case of request of information from Banks/Financial institutions through their forensic auditor or otherwise for information regarding financial assets etc of investor in matters related to diversion and or criminal liability related matters where a request is made from Senior person / Director level official of bank/FI etc to ascertain violation of any existing law .

g)     Certain Personal Information may be shared with post office, local & international courier service providers and other intermediaries for correspondence with the Provider of Information and for making payments to the Provider by cheques, drafts, warrants, through electronic clearing services, NEFT etc.

 

The User agrees and understands that when the AMC uses trusted third parties to act on the AMC’s behalf for performing certain functions such as processing transactions, issuing account statements, payment gateway services, customer services, data storage etc., contractual, or other means are used to ensure reasonable security safeguards appropriate to the sensitivity of the Personal Information, consistent with generally accepted standards of commercial business practice. The AMC would ensure to enter into suitable terms with third party service providers in order to protect client confidentiality and follow a non-disclosure or restricted disclosure policy.

 

The Personal Information so collected shall be communicated to third parties / third persons only for the reasons consistent with the purposes for which such Personal Information was originally collected or such purposes as authorized by law. it shall be the AMC’s foremost endeavour to ensure that your Privacy is protected at all points in time.

 

8.      Access to data:

 

Your account information is not permanently stored on the AMC’s Web server. The information only resides on the AMC’s Web server while the user is viewing the information. It is permanently stored on the AMC’s secured corporate computer systems. The AMC has data security staff whose sole responsibilities are to ensure the security of the information the AMC processes and stores. The AMC may outsource the activities pertaining to data storage and maintenance in compliance with the applicable laws for the time being in force.

 

The AMC / the Mutual Fund has policies and procedures in place to limit access to the User’s information to only those who have a business need to view it.

 

9.      Direct Marketing:

 

Any, non-personally identifiable visitor information may be provided to the third parties for marketing, advertising, or other uses. However, Personal Information shall not be shared for direct marketing without the express permission of the Provider of Information.

 

10.   Do Not Call Registry

 

In furtherance to your usage of the Website and/or our Services, you expressly waive the Do Not Call (DNC) / Do Not Disturb (DND) registrations on your phone/mobile numbers for contacting you. Hence, there is no DNC / DND check required for the number you have provided/ made available to AMC. Modes of contacting you/ communication may include sending SMSs, WhatsApp, email alerts and / or telephonic calls etc.

You unconditionally authorize the AMC, its affiliates, Vendors, service providers, facilitating agency and their representatives to call, send email, SMS, or communicate through WhatsApp about the Services and other updates/ offering from time to time.

​​​11.   Cookies

To enhance your experience with our website, we may use “cookies”. Cookies are text files that we may place in your computer browser to store your preferences. Cookies are used to record various aspects of your visit and assist us in providing you with uninterrupted service. One of the primary purposes of cookies is to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content. Most Web browsers automatically accept cookies, but you can usually modify the browser setting to decline cookies if you so prefer. If you choose to decline cookies, you may not be able to use one or more services offered through this Website that may depend on cookies.

You should be aware that we cannot control the use of cookies (or the resulting information) by third parties and use of third-party cookies is not covered by our Privacy Policy.

12.   Link to third parties

 

This Privacy Policy does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit. If you wish to request access to and correction of your personal data held by these websites, please contact these websites directly.

 

13.   Information Third Parties Provide About You

 

We may, from time to time, supplement the information We collect about you through our website with outside records from third parties in order to enhance our ability to serve you, to tailor our content to You and to offer you opportunities to use such of our Services that we believe may be of interest to You. We may combine the information we receive from such third-party sources with information we collect through the Website. In these cases, we will apply this Privacy Policy to any Personal Information received, unless otherwise provided.

 

14.   Monitoring and enforcement

 

The AMC takes appropriate security measures to monitor unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include internal reviews of the AMC’s/ the Mutual Fund’s data collection, storage and processing practices and security measures. The AMC would ensure to enter into suitable terms with third party service providers in order to protect client confidentiality and follow a non-disclosure or restricted disclosure policy. Further, the employees who violate the privacy and confidentiality promise shall be subjected to disciplinary action.

 

15.   Reasonable Security Practices for Protecting Information:

 

AMC uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information (including personal sensitive information). To protect your privacy and security, AMC take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account.

 

You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from AMC, at all times.

 

16.   Breach of Internet Security

All information gathered by the AMC/ the Mutual Fund is securely stored within the AMC’s controlled databases. The databases are stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. Despite our best efforts, if unauthorized persons breach our security control measures resulting in the Servers being hacked or presenting inaccurate information etc., AMC, their directors, officers, employees, or affiliates' will not be responsible.

17.   Exclusion

This Privacy Policy will not apply to any unsolicited information provided by you through this Website or through any other means. This includes, but is not limited to, information posted on any public areas of the Website. All such unsolicited information shall be deemed to be non-confidential, and the Company will be free to use, disclose such unsolicited information without limitation.

The Company also protects your personal information off-line other than as specifically mentioned in this Privacy Policy. Access to your personal information is limited to employees, agents, or partners and third parties, who the Company reasonably believes will need that information to enable the Company to provide Services to you. However, the Company is not responsible for the confidentiality, security, or distribution of your own personal information by our partners and third parties outside the scope of our agreement with such partners and third parties.

18.   Changes to Privacy Policy

AMC reserves the right to change this policy from time to time. Any changes shall be effective immediately upon the posting of the revised Privacy Policy. We encourage you to regularly check this notice on our website for updates.

19.   Grievance Redressal:

In case you have any concerns relating to their personal and sensitive information they may be addressed to Mr. Kiran Deshpande, COO & CFO of the AMC, at kiran.deshpande@barodamf.com. In case if you feel that your concerns are not adequately redressed by the Grievance Redressal Officer within 30 days of lodgement of complaint, you may escalate the same to Mr. Suresh Soni, CEO of the AMC, at suresh.soni@barodamf.com.​


 Investors/clients/customers shall have expressly consented to the terms of this Policy if they enter and use this website or provide any information while transacting with us.​







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