1. Introduction and Scope
Sanriya Finvest Private Limited respects your privacy. We are a Data Fiduciary under the Digital Personal Data Protection Act, 2023. This policy applies to this website, to our mobile application and to every service we provide to you.
Where you provide information by which you can be identified, it will be used only in accordance with this policy.
2. What We Collect
We follow the principle of data minimisation and collect only the information necessary to meet our regulatory and operational responsibilities.
▪ Identity and contact details: name, date of birth, permanent account number, address, mobile number and e-mail address.
▪ Financial and transactional details: bank account details, income range, occupation, tax residency status, KYC identifiers, folio numbers and transaction history.
▪ Suitability details: the answers you give in your risk profile and your investment preferences.
▪ Nominee and beneficiary details: provided by you with your knowledge and consent. You are responsible for ensuring that these details are accurate, complete and current. Any request to change or correct such information must be communicated to us within 7 working days so that the necessary update can be initiated. Sanriya Finvest relies on the information and instructions provided by you and is not responsible for any loss or consequence arising from incorrect, incomplete or outdated information or instructions provided by you.
▪ Technical details when you use this website: internet protocol address, browser type, device information, the pages you visit and the average time spent on them.
3. Why We Collect It
▪ To complete your Know Your Customer formalities and to open and service your folios.
▪ To place and track the transactions you instruct, and to send you statements, valuation reports and service communications.
▪ To record your risk profile and to offer you a review of it.
▪ To answer your queries and to resolve your complaints.
▪ To diagnose problems with our servers, to alert you to compatibility issues, and to improve the design and functioning of this website.
▪ To meet the obligations placed on us by law and by the regulators of the securities market.
4. Legal Basis and Consent
▪ We process your personal data on the basis of your consent, of our legal obligations under SEBI, AMFI, APMI and Prevention of Money Laundering Act requirements, and of our contractual obligations to you.
▪ Your data is collected with notice and with your consent.
▪ You may withdraw your consent at any time by writing to services@sanriya.net.
▪ Withdrawal does not affect anything lawfully done before it, and may mean that we can no longer service your folios.
▪ Where a law requires us to collect or retain data, we hold it for as long as that law requires.
5. Whom We Share It With
▪ The Asset Management Company whose scheme you invest in, and its Registrar and Transfer Agent.
▪ The transaction platform through which your order is placed.
▪ The KYC Registration Agency and the Central KYC Registry.
▪ Our approved information technology and compliance service providers, and our professional advisers where required, in each case under written confidentiality obligations.
▪ Any court, regulator, tax authority, government body or law enforcement agency entitled to the data in law.
We do not sell your data, we do not rent it, and we do not share it for anyone’s marketing purposes.
6. How We Protect It
▪ Data is held on access-controlled, password-protected systems, with passwords one-way encrypted before they are stored.
▪ Communication with you, with Asset Management Companies and with other service providers is encrypted in transit using industry-standard protocols, and this website is secured with an SSL certificate.
▪ Our data is hosted with established hosting service providers and our records are backed up at regular intervals to ensure continuity of operations.
▪ Access is given only to those personnel who need it for their work. Every person who joins us signs a confidentiality undertaking, and our service providers are bound by written terms requiring them to protect the data they hold for us.
▪ No method of storage or transmission is completely secure. While we take reasonable physical, technical, electronic and managerial measures, we cannot guarantee absolute security.
7. Data Breach Notification
In the event of a data breach, we will notify the investors affected, report the incident to the regulators as required, and take containment and corrective measures.
8. How Long We Keep It
▪ For as long as you remain our client, and thereafter for the period that applicable law requires records to be preserved.
▪ When the retention period ends, the data is deleted or anonymised.
9. Your Rights
▪ To ask for the personal data we hold about you and a summary of how it has been processed.
▪ To have inaccurate data corrected and incomplete data completed.
▪ To have your data erased where we are no longer required to keep it.
▪ To withdraw your consent to its processing.
▪ To manage your communication preferences and to opt out of promotional communications at any time.
▪ To nominate another person to exercise these rights on your behalf in the event of your death or incapacity.
To exercise any of these rights, write to services@sanriya.net. We respond within the time allowed by law, and requests for erasure remain subject to the record-retention obligations set out in Section 8.
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10. Children
We do not knowingly collect data directly from a child. Where an investment is made for a minor, the folio is operated by the guardian, who is responsible for providing accurate and complete information, giving the necessary consent, and making investment decisions on behalf of the minor. Sanriya Finvest processes such information based on the guardian’s instructions and consent and is not responsible for inaccuracies or decisions arising from information or instructions provided by the guardian.
11. Cookies and Analytics
This website uses cookies and analytical tools to keep the site working, to remember your preferences, and to understand how the site is used and how our campaigns perform. We may engage third-party analytics providers for this purpose; they do not collect personally identifiable information on our behalf. You may block or delete cookies through your browser settings, though some parts of the site may then not work as intended.
12. Links to Other Websites
This website links to the websites of Asset Management Companies, exchanges, registrars and regulators. Once you leave our site through such a link, we have no control over that website and are not responsible for its privacy practices or for the protection of any information you provide there. You should read the privacy statement of the website in question before providing information to it. We are not responsible for any hyperlink to our website set up by a third party.
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13. Changes and grievances
We may amend this policy from time to time. The amended policy takes effect when it is published on this page.
For any question or grievance about the handling of your personal data, write to Mr. Santosh Kedari, Director, at spk@sanriya.net or telephone +91 70663 31155.
We acknowledge within 3 working days and respond within 15 working days.
If you are not satisfied with our response, you may approach the Data Protection Board of India under the Digital Personal Data Protection Act, 2023.
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14. Policy Review and Updates
This policy is reviewed annually, and upon any change in SEBI, AMFI, APMI or data protection law. We may amend it at any time; the amended policy takes effect when it is published on this page. You are advised to review this page periodically.
15. Disclaimer
Mutual fund investments are subject to market risks. Read all scheme-related documents carefully before investing. Sanriya Finvest Private Limited acts solely as an AMFI-registered Mutual Fund and Specialised Investment Fund Distributor (ARN-193359) and an APMI-registered Portfolio Management Services Distributor (APRN-01056)
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