Privacy Policy

This Privacy Policy (“Policy”) sets out how Neo Markets Services Private Limited (hereinafter “Company”) uses and protects any Information (both personal and non-personal information per the Information Technology Act, 2000 and the Information Technology Rules, 2011) that you give the Company when you access the website of the company and register for the services of the company. The Company is strongly committed to protecting the privacy of the User (hereinafter “you” and “your”)

You are advised to read and understand our Privacy Policy carefully, as by registering with us you agree to be bound by this Privacy Policy and consent to the collection, storage, use and transfer of your information as provided herein. This Policy is incorporated into and subject to the Terms and Conditions of the Website.

If you object to this Privacy policy as provided herein, including the collection and processing of your information, please do not provide the details of your information on the Website (or “Platform”).

Kindly note that this privacy policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.

I) Types of Information the Company Collects:
The Company collects your information for providing services in various ways such as:

i) Account:
The Company collects and associates your account’s information with your Name, gender, residential or correspondence address, telephone number, date of birth, marital status, email address or other contact information; PAN, KYC Status, Signature and Photograph. It further collects details about registration of multiple bank accounts etc. through application forms, Payment instrument details at the time of submitting application for investment or as proof for carrying out change of bank account or any other details of debit card obtained (if any), Generation and storing password (PIN) in encrypted form based on the request from the investor under the online mode of investments, Annual Income and savings profile, Financial information such as Bank account, credit card, debit card or other payment instrument details. The Company may also collect Your Aadhaar, finger - print details and signature solely for completing the account opening procedures and authenticating Your transactions on the Platform. The act of providing Your Aadhaar is voluntary in nature and the Company, hereby agrees and acknowledges that Company will collect, use and store such details in compliance with applicable laws and this Privacy Policy.

ii) Website Related Use:
The company collects information through your use of the Company’s services or through data provided by you for any queries arising out of the Company’s services to optimize your experience. The company further collects information of your use of platform for trading stocks. The company shall also collect information through your use of the Company’s platform for buying, selling, redeeming mutual funds units or stocks by transmitting money, providing instructions to AMCs for execution of your transactions.

iii) Cookies and other technologies:
When you register with or view the Company’s website, the Company’s servers automatically record certain information that your web browser sends whenever you visit the Company’s website. The kind of information that is gathered automatically include the domain name of your Internet Service Provider, the date and time of your visit and the pages on the Company’s website that you visit. The Company may sometimes use this information to improve the website(s) design, content and primarily to give you a better browsing experience. If you prefer to restrict, block or delete cookies from this website, or any other website of the Company, you can use your browser to do this. Each browser is different, so check the 'Help' menu of your particular browser to learn how to change your cookie preferences. If you choose to disable all cookies the Company shall not guarantee the performance of the Company’s website. The Company does not control use of such technologies used by advertisers and partners and it expressly disclaims responsibility for information collected through them.

iv) Storage Information:
The company facilitates you to download and display information such as scheme commission details which you may refer to, or to upload relevant documents as per various processes during your account management or transaction order placement.

v) Media Information:
The company facilitate users to capture, upload relevant documents as may be required to be uploaded during user account management or transaction order placement.

vi) Device Information:
The company collect specific information about your device when you access our Services, including your storage, hardware model, operating system and version, unique device identifier, mobile network information, location, contacts and information about the device’s interaction with our services.

vii) Necessary Information:
The Company also collects information necessary for AMC/Service Providers to respond to your requests, to process the investment applications and to also ensure safe subscriptions/redemptions through points of acceptance in physical form, website, online portals, Automated Teller Machines and such other mode.

viii) Third-party:
The Company collects information about you from third parties. Further, the company collects Information about you through call recordings at our call centre(s), Internet technologies, including our website.

ix) Surveys:
The Company may occasionally ask You to complete optional online surveys. These surveys may ask You for Your contact information and demographic information (like zip code, age, or income level). The Company uses this information to tailor Your experience at the Platform, providing You with content that the Company thinks You might be interested in and to display content according to Your preferences. The Company uses Your Personal Information to send You promotional emails, however, we will provide You the ability to opt­ out of receiving such emails from Us. If You opt out, the Company may still send You non- promotional emails, such as emails about the Services and Your account on the Platform. Unless and until, You explicitly give Your consent to the Company, to do so, the Company shall not share Your Personal Information with another user of the Platform and vice versa.

II) How the Company uses your Information
The Company shall use your information as:

i) General Use: In general, the information you submit to the Company is used either to respond to requests that you make, or to aid the Company in serving you better. The Company may use your information in the following ways:
(a) to provide and improve the Services on the Platform that You request;
(b) to provide any services to which you subscribe and any ancillary or related activity;
(c) to identify you as a user in the Company’s system;
(d) to resolve disputes and troubleshoot problems;
(e) to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users;
(f) collect money from you in relation to the Services;
(g) to facilitate the creation of and secure your user account;
(h) to keep you updated about the Company's new product or information;
(i) to inform you about online and offline offers, products, services, and updates;
(j) to process your trading request;
(k) to carry out settlements of your obligations;
(l) to customize your experience on the Platform or share marketing material with you;
(m) to process and fulfil your request for Services or respond to your comments, and queries on the Platform;
(n) enforce and inform about the Company’s terms and conditions;
(o) to contact you;
(p) to detect, prevent and protect the Company from any errors, fraud and other criminal or prohibited activity on the Platform;
(q) to allow the Company to present customised messages to you;
(r) to identify your IP address to help identify you and gather broad demographic information;
(s) to identify your IP address to help diagnose problems with the Company’s server and resolve such problems and administer the Platform.
(t) to communicate important notices or changes in the Services, use of the Platform and the terms/policies which govern the relationship between You and the Company for providing Services to you; and
(u) to send you administrative e-mail notifications, such as security or support and maintenance advices;

ii) The Company may also use and share aggregated or de-identified information for any purpose and in any manner. This aggregated or de-identified data that the Company shares may include non-personally identifiable data that the Company creates using your personal information by excluding information that makes the data personally identifiable.

iii) The Company shall also collect information to be compliant with the Know Your Client (KYC) norms under the Prevention of Money Laundering Act, 2002, (PMLA), the rules issued thereunder, and guidelines and circular on Anti- Money Laundering issued by SEBI and SEBI (Mutual Funds) Regulations, 1996 as amended till date.

III) How the Company shares Information
The Company may share information as per the terms of this Privacy Policy. The Company does not share your personal information with third parties other than as follows:
a) Others working for the Company: The Company shall disclose your information to third-party vendors, consultants, and other service providers who work for the Company, who are bound by contractual obligation to keep such personal information confidential and use it only for the purposes for which the Company discloses it to them. This disclosure may be required to provide you access to the Company’s services and process payments including validation of your bank accounts, to facilitate and assist the Company’s marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to the Company’s Services.
b) Affiliates: The Company may share your information with its subsidiaries and/or affiliates who are bound by contractual obligation to keep such personal information confidential and use it only for the purposes for which the Company discloses it to them.
c) Subcontractors: The Company may share your information with subcontractors. In doing so, the Company would take reasonable care as required by law, but the company does not warrant that such parties would use the information obtained from the Company for required use exclusively.
d) Third Parties: The Company may also share certain information with third parties to add value and improve the quality of services imparted by the Company. The Company shall take all reasonable steps to ensure that the confidentiality of your information is maintained by imposing strict confidentiality standards on all the third parties with whom we part this information.
e) Reviewing and Processing: The Company may transfer and share information (including Personal Information) related to You with third parties including but not limited to Banks, financial institutions, credit information companies, Real Estate Developers, Real Estate Companies, entities registered under applicable laws with Securities Exchange Board of India, National Stock Exchange of India Limited, Bombay Stock Exchange, Maharashtra Real Estate Regulatory Authority, Central Registry of Securitization Asset Reconstruction and Security Interest of India (CERSAl), payment gateways, collecting banks, KYC Registration Agencies (KRAs) solely for the purpose of reviewing your profile and processing your transaction requests for the Services or for such other products/services offered by the Company.
f) Law and Order: The Company shares data as part of legal and regulatory requirements of Securities and Exchange Board of India, National Stock Exchange, Bombay Stock Exchange, Central Depository Securities Limited, National Securities Depository Limited, Depository, Depository Participants, Ministry of Corporate Affairs, Reserve Bank of India, Registrar, Transfer Agents, Mutual Funds Agents, KYC agents, Asset Management Companies of Mutual Funds, Collecting Banks, KYC Registration Agencies (KRAs), Maharashtra Real Estate Regulatory Authority or any regulatory or government authorities, or other third parties invited to participate in any offers for the benefit of users of services of the Company. The Company may, to the extent necessary, share your information to comply with laws and to respond to lawful requests and legal process and to protect the rights and property of the Company, the users, including to enforce the Terms and Conditions.

IV) Storing of your Information
a) Retention: The Company may retain your information for as long as it needs.
b) No warranty: The Company uses commercially reasonable safeguards to help keep the information collected by the Company secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, no method of transmission over the internet, or method of electronic storage, is 100% secure and so the Company cannot fully ensure or guarantee the security of any information you transmit to the Company or guarantee that information may not be accessed, disclosed, altered, or destroyed by any person.
c) No liability for external websites: The Company’s website sometimes may have links to other website(s) in the World Wide Web. The privacy policies of these website(s) are not under the Company’s control. Once you leave the Company’s servers, any information you provide is governed by the privacy policy of the operator of the website you are visiting. The Company does not warrant security of your information when visiting external websites including those that have a link on the Company’s Website.

V) Changes
The Company may share, sell, transfer, license or convey some or all of your information in connection with or during negotiation of any merger, financing, acquisition or dissolution, collaboration, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of its business or assets. In the event of an insolvency, bankruptcy, or receivership, your information may also be transferred as a business asset. If another entity acquires the Company or its business or assets, that entity will possess all your information collected by the Company and will assume the rights and obligations regarding your information as described in this Privacy Policy.

VI) Amending your Information
You may upon written request to us review the sensitive personal data or information provided. The Company shall ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible.

VII) Safety
In the event of any unforeseeable circumstances, the Company is in no manner responsible for informing you or seeking your consent to protect the personal safety and assets of the Company, the users, or any person. The Company in such an event may, in compliance with applicable laws, share, transfer, assign all or any of your information.

VIII) Minors
This website is not intended for use by minors. Parents are requested to ensure that Personal Information is not provided by minors.

IX) Right to opt-out
You always have the right to refuse or withdraw your consent to share or to disseminate your information by contacting the customer care. However, in such an event, you shall no longer avail the services of the Company. The withdrawal of consent shall not affect the lawfulness of processing of your data based on consent before its withdrawal. Thus, opt out request would not be applicable to the correspondence and communications already initiated by the Company.

X) Changes to our Privacy Policy
Please note that this policy may change from time to time. If the Company change its privacy policies and procedures, the Company shall post those changes on its website, platform to keep you aware of what information the Company collects, uses, discloses. Changes to this Privacy Policy are effective when they are posted on this page and the last updated Policy shall be applicable to you. Certain sections or pages on this website may contain separate privacy policy, which is in addition to this privacy policy. In the event of any conflict between the two, the additional privacy policy shall govern those sections or pages.

XI) CONTACT
If You have any queries or complaints with respect to the Platform, please feel free to reach out to the Customer Care , the name and contact details of the Head-Customer Care have been provided below:
Assistant Vice President, Customer Care, Neo Group
Email id: vishaka.poojari@neo-group.in
In case of escalations, please reach out to :
Official: Chief Compliance Officer, Neo Group
Email id : vishaka.poojari@neo-group.in