Trivantage Capital Management India Private Limted (hereinafter “Trivantage Capital”), in the course of its business and while dealing with the investors, vendors, distributors (hereinafter “Provider of Information/ Provider”) may become privy to the personal information of the Provider of Information, including information that is of a confidential nature.
The Personal Information that Trivantage Capital collects from the Provider of Information may include information that is of a confidential nature, and shall mean and include any information that relates to a person, which either directly or indirectly, in combination with other information that is available or likely to be available to Trivantage Capital, is capable of identifying the Provider of the Information (“Personal Information”).
- Full name
- Telephone number(s)
- E-mail address
- Password (in the event of the Client signing up for the online facilities)
- Financial information (pertaining to the investments/ applications/ transactions and any other related purposes vide which Trivantage Capital would be providing the services to the Investors);and
- Any other information as defined under Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011,
- as may be required by Trivantage Capital from time to time in order to provide services to the Provider of Information.
However, any information that is freely available in the public domain is exempt from the above definition.
The Provider of Information herein shall have the right to approach and modify the Personal Information that has been retained with Trivantage Capital. Please note, that Trivantage Capital shall not be responsible for the accuracy of the information that is being provided by Clients.
Collection of Personal Information
Personal Information is collected and/or obtained by Trivantage Capital from several sources, wherein the Provider of Information has provided for the same. The information provided may include such Personal Information as a part of the application and/or enrollment process (the same maybe online or vide a physical application form).
Additionally, Trivantage Capital may obtain the Personal Information from third-parties, or though call recordings at our office/s, internet technology, including our Website.
Information shall also be collected from vendors/ distributors and/or any other service providers for maintenance of our records and for processing of the payments/ commissions etc.
The Provider of Information agrees and understands that the Personal Information collected by Trivantage Capital shall be processed, stored and used by it, and the same may also be passed to, transmitted to and processed by its affiliates and other data processors, agents or service providers acting under a contract with Trivantage Capital for the purposes identified herein.
Security Standards and Measures:
Trivantage Capital has adopted reasonable security practices and procedures and have implemented such reasonable security practices and safeguards which are appropriate to the sensitivity of the Personal Information.
These security practices and standards are consistent with generally accepted standards of commercial business practice, which includes technical, operational and physical security control measures which commensurate with the Personal Information being protected from any unauthorized access and/or disclosures while the same is with Trivantage Capital.
The Provider of Information agree and understand that trusted third parties who act on Trivantage Capital’s behalf for performing of certain functions such as processing of transactions etc. are under contractual obligations to ensure reasonable security safeguards commensurate to the sensitivity of the Personal Information being handled by them.
Trivantage Capital endeavours to safeguard and ensure the security of the information provided by the Provider of Information.
Use of Personal Information:
The Provider (s) expressly agree and understand that:
Trivantage Capital may use the Personal Information of the Provider for the purposes of providing him with the services to which he has subscribed and any service- related activities such as processing instructions, responding to service requests, resolve any grievances etc. The same may also be used to contact clients whenever required and also to seek feedback from clients in relation to the offered services.
The Contact information (like e-mail address, phone number, etc.) may be used to send periodic information on the services or upcoming events or announcements.
The Personal Information may be used to generate statistics and reports for both internal use and for sharing with affiliates, intermediaries, successors, vendors, service providers and advertisers. Such statistics and reports will not contain Personal Information that could identify the Provider of Information, personally.
Disclosure of Personal Information:
Trivantage Capital may disclose the Provider’s information in order to:
- Conform to legal and/ or statutory requirements or comply with legal process;
- Protect and defend Trivantage Capital’s rights, interests or property;
- Enforce Trivantage Capital’s legal rights, terms and conditions or provisions of the disclosure document / product term sheet and literature of its Portfolio Management and Advisory Services / any other products or services.
Sharing of Personal Information with Third Parties:
To the extent required or permitted under law, Trivantage Capital may share the Investor’s Personal Information for the uses mentioned here with the following third parties:
- Banks, custodians, fund accountants, depositories, auditors and/ or authorized external third parties who are involved in transaction processing, dispatches, etc., of clients’ investment with Trivantage Capital and/or who are vendors/ service providers / distributors to whom commission is paid;
- Distributors or sub-brokers or intermediaries through whom applications are received and whose ARN number is stamped on the application form/ transaction slips;
- Any other organization for verifying the identity of investors for complying with anti-money laundering requirements;
- Any governmental authority including but not limited to the Reserve Bank of India and/ or the Securities and Exchange Board of India;
- Certain Personal Information may be shared with post office, local & international courier companies
- 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.
Trivantage Capital shall, on a best effort basis, ensure that Personal Information is transferred to the third parties, on an assurance from them that reasonable and appropriate steps have been taken to maintain the required level of data protection.
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.
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.
Retention of Personal Information
Trivantage Capital may retain Provider’s Personal Information for as long as required to provide our services to the client or otherwise if required under law.
Breach of Internet Security
In addition to the efforts of Trivantage Capital, for the protection of the Personal Information, it is important that the Provider of Information should co-operate with Trivantage Capital for the security of the Personal Information.
It is recommended that the Providers should necessarily choose their passwords carefully such that no unauthorized access is made by any third party and not to disclose the same to any one and or keep a record of the same in writing.
However, despite Trivantage Capital’s best efforts, if unauthorized persons breach our security control measures resulting in the website being hacked or presenting inaccurate information etc., Trivantage Capital will not be responsible.
All such incidental information will be used only to assist Trivantage Capital in providing an effective service on the Website.
Any grievance relating to your Personal Information may be addressed to the Investor Relations Officer.